Should a product passport sit in a QR code, a tag, or both?
Start from the act, which specifies one or more carriers for the group. Where it leaves room, the printed symbol costs nothing per unit and any camera reads it, while a tag survives wear, reads without aiming and can sit inside the product. Many products end up carrying both.
Both are carriers, by definition
regulation (EU) 2024/1781 defines a data carrier as a linear barcode symbol, a two dimensional symbol or other automatic identification data capture medium that can be read by a device, and Article 9 leaves the delegated act to specify one or more carriers for the group, their layout and their positioning. Neither medium is privileged by the definition.
So the first move is not a comparison: it is reading the act. Where it names a carrier, the question is closed, and where it allows more than one, the comparison below is what remains.
What separates them
A printed symbol costs nothing per unit beyond the printing, and every phone reads it with a camera and no application. It needs light, a line of sight, a clean surface and an intact print, which is exactly what a product in use stops providing.
A tag costs a component and a placement, reads without aiming and through most non metallic materials, and can sit inside the object where nothing rubs it away. It is read by phones with the hardware, which the comparison page weighs for the general case, and it survives a decade of handling better than ink.
Carrying both without carrying two
The two carriers can hold the same identifier, which keeps one resolver, one record and one destination behind both. A product that prints one address and encodes another has two systems to keep alive for the life of the product, and the availability requirement makes that mistake expensive.
Where they differ is who arrives: the printed symbol serves the customer with any phone, the tag serves the repairer, the recycler and the line worker who taps without looking. That is one identifier with two doors, which is the arrangement most products end up with.
When the text names one
regulation (EU) 2023/1542 shows what it looks like when a text does choose. Article 13 requires batteries to be marked with a QR code from 18 February 2027, and Article 77 says the battery passport is accessible through that QR code, which links to a unique identifier. A tag can be added for other purposes, but the access point the text names is the printed one, which the battery page covers.
Read your act the same way before designing anything: what it names, where it says the carrier goes, and at which level the passport is established.
Frequently asked questions
Can I choose the carrier freely?
Only where the act allows it. The delegated act for the group specifies one or more carriers, their layout and their positioning.
Is a tag better than a printed code?
For a product in use, it survives wear and reads without aiming. For reach, a printed code is read by any camera. Many products carry both.
Should both carriers hold the same identifier?
Yes, where both are used. One identifier behind both keeps a single resolver and a single record to keep alive.
Does any text name a specific carrier?
The batteries regulation does: the battery passport is accessible through the QR code that batteries have to carry from 18 February 2027.