Advisor to the law firm “Tegos,” lawyer Aleksandra Fedotova emphasizes that QR codes are not an alternative to mandatory information.
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“QR codes are becoming popular, but they cannot be used to hide information that must be provided directly on the packaging. If the consumer needs to see that information, it cannot be transferred to a QR code just because it is more convenient for the company,” says A. Fedotova.
When it is appropriate and when it is not
According to lawyers, QR codes can be used additionally to provide detailed information – for example, research data or a broader explanation of the product’s effects. However, essential statements must be clearly indicated on the packaging itself.
“Tegos” Retail and Wholesale Group Manager, lawyer Indrė Barauskienė gives an example:
“If it is claimed that the CO2 amount was reduced during the production process and this is supported by data, more detailed information about this can be provided in the QR code. However, if the packaging states that the product packaging is recyclable, such important information as, for example, that only 10% is recyclable cannot be hidden in the QR code. Such practice would already be considered misleading,” says I. Barauskienė.
What is omitted is also important
Lawyers emphasize that misleading consumers can include not only incorrect statements but also omitted information. If important data is hidden in additional channels – for example, in a QR code or on the company’s website – this can be considered misleading practice.
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“The consumer should not be forced to search for essential information. It must be provided clearly and immediately. The QR code can only supplement it, but not replace what must be indicated on the product,” notes A. Fedotova.
I. Barauskienė points out that information about the product’s environmental impact is becoming increasingly sensitive to consumers, so higher transparency requirements are imposed on it.
“For example, a product may be presented as environmentally friendly, but certain aspects of its production or supply chain may have a significant negative impact. In such cases, it is important that communication is complete and does not create a misleading overall impression,” says I. Barauskienė.
With growing attention from regulators and consumer awareness, it is becoming increasingly important for businesses to ensure that information communicated about the environmental impact of products is not only attractive but also accurate and clear – both on the packaging and beyond.
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