GS1 Sunrise 2027: Implementation Guide
Knowing GS1 Sunrise 2027 is coming is one thing. Actually getting your labels compliant — on time, correctly specified, and tested — is another. This guide walks through every step of a GS1 Sunrise implementation from initial product audit to verified print sign-off.
If you haven’t read our GS1 Sunrise overview yet, start there. This guide assumes you understand the basics and are ready to act.
Step 1: Confirm Your GS1 UK Membership and Company Prefix
Before anything else, verify your GS1 UK membership is current and your company prefix is live. Visit gs1uk.org to check. If your membership has lapsed or you’ve never joined, this is your first action — everything downstream depends on a valid GS1 company prefix.
Your prefix is the foundation of every GTIN on every product in your range. Without a valid, active prefix, you cannot generate compliant GTINs for your 2D codes, and you cannot pass GS1 verification.
If you’re new to GS1, joining costs from around £100 per year for small producers and takes a few days to process. Factor this into your planning timeline.
Step 2: Audit Your Product Range for Sunrise Scope
Not every product in your range needs the same level of attention. Work through your range systematically and create three groups.
Priority 1 — Must act: Products sold through retail channels, particularly major multiples. These are the products where retailers will enforce Sunrise 2027 requirements earliest and most strictly.
Priority 2 — Should act: Products carrying variable data — batch numbers, expiry dates, use-by dates, lot codes. These products benefit most from dynamic 2D codes and are likely to be targeted by retailers requiring encoded traceability data.
Priority 3 — Lower urgency: Non-retail, non-variable products. These still need a compliant 2D code eventually, but can follow the Priority 1 and 2 programme rather than driving it.
Check retailer-specific guidance as you do this. Some customers will have published their own Sunrise 2027 requirements — Tesco, for example, has been piloting GS1 Digital Link QR codes in live retail environments. Their specification may exceed the GS1 baseline. Contact your key retail customers directly and ask for their Sunrise requirements in writing.
Step 3: Choose Your 2D Code Format — DataMatrix or QR
For most FMCG and manufacturing applications, the choice is between GS1 DataMatrix and GS1 QR Code (also called GS1 Digital Link QR).
GS1 DataMatrix is the standard choice for non-consumer-facing labels, industrial applications, and products where label space is tight. It encodes dense data in a compact square symbol. It is the format recommended by GS1 for most product labelling transitions and is the format most retail scanning hardware is already equipped to read.
GS1 Digital Link QR Code encodes a web URL following the GS1 Digital Link standard, enabling the code to be scanned by both retail POS systems and consumer smartphones. It links the physical product to a digital product page containing real-time information — nutritional data, allergen information, sustainability credentials, promotions. If consumer engagement, digital product passports, or retail data requirements are part of your roadmap, GS1 Digital Link is the format to target.
The decision affects your data architecture as well as your label design. Confirm the right format with your label supplier before briefing artwork.
Step 4: Make the Static vs Dynamic Decision
This is the most consequential technical decision in the whole process, and it needs to be made before briefing artwork.
Static 2D code — the same symbol on every label in a run, encoding only your GTIN. Your EAN-13 barcode is already static. A static 2D code adds a compliant 2D symbol without changing your label printing process. For pre-printed label rolls, this is the lowest-friction route to Sunrise compliance.
Dynamic 2D code — a unique symbol on every label, encoding your GTIN plus variable data: batch number, expiry date, use-by date, serial number. This is where the supply chain value of Sunrise sits. Retailer stock rotation based on actual encoded expiry dates, batch-level recall capability, serialisation for anti-counterfeiting. Dynamic 2D requires on-demand digital printing at your line, not pre-printed rolls.
Two things push strongly toward dynamic. First, if any of your products have expiry or batch data, the retailer benefit of encoded variable data is significant and some retailers will eventually require it. Second, EU Digital Product Passport requirements (coming in stages from 2026 onward) will require serialised product data for several categories — if you sell into European markets, going dynamic now means you don’t revisit this decision in 18 months.
If you’re uncertain, speak to Positive ID Labels. The choice has real operational implications and it’s worth getting it right first time.
Step 5: Plan the Label Layout Before Touching Artwork
Do not open artwork until you’ve mapped your label zones on paper. A GS1 Sunrise-compliant label for a product that’s also in scope for the Deposit Return Scheme needs to accommodate:
- Your existing EAN-13 barcode
- A GS1 2D code within 50mm of the EAN-13 centre
- The Exchange for Change scheme logo (DRS mandatory)
- A DRS machine-readable identifier (DRS mandatory)
- All existing mandatory content — allergens, nutrition, recycling marks, regulatory text
On a 330ml can or a small PET bottle, that’s five distinct elements competing for space that was already tight before any of this was required.
The planning order matters. Start with every mandatory element and the space each requires — including quiet zones — and map them against your available label area. If they don’t fit, the answer is a layout reconfiguration, not squeezing elements together until they fail.
The 50mm placement rule for the GS1 2D code is a hard specification, not a guideline. It exists to ensure both codes sit within the scanner field simultaneously at retail POS. There is no valid artwork that places the 2D code outside this radius.
Step 6: Assess Your Print Process and Substrate
A 2D code is not just a smaller barcode. The tolerance requirements are tighter, the module precision is higher, and the print consistency needs to be more controlled. Your existing label materials and print process may not meet the spec without changes.
What to check with your label supplier:
Dot gain — most print processes produce slightly larger dots than specified. For 1D barcodes, a small amount of dot gain is manageable. For 2D codes, excessive dot gain distorts module edges and reduces readability. Measure your process’s dot gain and assess whether it’s within acceptable range for your minimum module size.
Contrast ratio — the difference in reflectance between the dark modules and the light background needs to meet GS1 minimum requirements. This is affected by ink type, substrate colour, and coating. Don’t assume it — test it.
Substrate stability — for dynamic variable data printing at line, the substrate needs to accept on-demand print (usually thermal transfer) cleanly and hold fine detail. Film substrates generally outperform paper here, particularly for any product going through refrigeration, condensation, or wet environments.
Resolution — smaller 2D codes on small containers require higher print resolution than larger codes. Confirm your print resolution against GS1 minimum module size requirements for your specific container dimensions.
If you’re moving to dynamic printing, the substrate assessment is part of the equipment specification for your on-demand printer. Positive ID Labels can supply materials spec’d for both pre-printed and on-demand applications.
Step 7: Brief Your Artwork Supplier
Once you’ve confirmed format, static vs dynamic, placement mapping, and substrate specification, you’re ready to brief artwork. A well-structured brief avoids revision cycles and ensures your artwork agency or internal team doesn’t have to guess at specifications.
Your brief should include: the 2D code format (DataMatrix or QR, including whether GS1 Digital Link), static or dynamic, the minimum code size for your container dimensions, the 50mm placement constraint relative to the existing EAN-13 centre, quiet zone requirements on all sides, substrate and print process for context, and whether any existing label content needs to move to accommodate the new elements.
If your products are DRS in-scope, include the Exchange for Change logo specifications and DRS machine-readable identifier requirements in the same brief. Do not run these as separate artwork instructions — the only way to know all elements fit together is to brief them together.
Step 8: Conduct Barcode Verification Testing Before Sign-Off
This step is non-negotiable. Do not commit to a full production run based on a print proof alone.
Barcode verification uses an ISO-compliant grading system (ISO/IEC 15415 for 2D codes) to produce an objective quality grade for each code on your printed sample. The grade runs from A (highest) to F (fail). For retail supply, you should be targeting Grade A or B.
Verification catches problems that visual inspection misses entirely: contrast that looks fine to the eye but fails at speed scanning, module edge degradation from dot gain, quiet zone violations that pass casual review but fail scanner detection, and encoding errors that won’t be apparent until a barcode reader actually processes the data.
Get production-quality samples printed on your intended substrate, on your intended print process, and send them for verification before sign-off. If you’re making changes to substrate or print process to meet the 2D spec, verify after the change — not on your old materials.
Positive ID Labels can arrange barcode verification testing. Ask us when you’re approaching print approval.
Step 9: Obtain Written Confirmation from Your Label Supplier
Once you have a verified, approved artwork file and a confirmed material and print specification, get written confirmation from your label supplier that your specification meets GS1 Sunrise 2027 requirements. This should cover:
- Placement within 50mm of EAN-13 centre confirmed
- Quiet zones compliant on all sides
- Minimum module size meets GS1 specification for your print process
- Print contrast meets ISO/IEC 15415 requirements on specified substrate
- Barcode verification grade achieved (A or B)
This written confirmation is your compliance audit trail. If you’re ever challenged by a retailer, a trading standards authority, or a customer, you need documentation that you took reasonable steps to ensure compliance — not just a print proof.
Your Q2 2026 Deadline Is the Real Constraint
Everything above needs to be complete — not in progress, complete — by mid-2026 for products going to market in the second half of the year. Containers printed with compliant labels in Q3 2026 will still be in retail in October 2027 when the Sunrise target date is reached.
If you’re reading this in early 2026 and haven’t started, you’re not too late — but you need to move. The steps above are sequential and some take longer than expected: retailer specification requests take time to come back, artwork revisions run to multiple rounds, substrate testing takes weeks, and verification testing adds time before sign-off.
Start with Steps 1 and 2 this week. Get your product scope clear and your GS1 membership confirmed. Everything else follows from there.
Download the Free 2027 Label Compliance Checklist
We’ve produced this free GS1 Sunrise 2027 implementation checklist covering every GS1 Sunrise 2027 requirement, designed to be used in your packaging team briefing and your conversation with your label supplier.
All labelling guides are provided in good faith for information purposes only and do not constitute legal advice. For specific compliance questions about specific labelling laws, contact a specialist or contact your local Trading Standards authority. Read our Regulatory Information Disclaimer