2D Barcode Sunrise 2027 Comes Fast: POS and Recall‑Ready Labels for Hemp‑THC Beverages You Must Build in 2025

In 2025, the “2D barcode at checkout” conversation stopped being a future-looking innovation project and became an operational deadline for brand owners who want mainstream retail distribution.

GS1 US has set a widely adopted target known as the 2D Barcode Sunrise 2027: by 2027, retailers and solution providers are expected to be able to scan a 2D barcode (most commonly a QR code or DataMatrix) at the point of sale (POS) for primary identification—meaning the same scan can support price lookup and item identification, and (when properly implemented) unlock richer data such as lot/batch, expiration date, and recall workflows.

For hemp‑THC beverages, this matters for two reasons:

The category is increasingly trying to reach grocery, club, and convenience channels that run strict item setup and scan‑rate programs.
Many states already require (or strongly encourage) consumer‑facing access to certificates of analysis (COAs) and product details via a QR code, creating label crowding and a risk of “QR chaos” if brands treat these as separate, unmanaged codes.

This article explains how to build a GS1 Digital Link migration plan in 2025 that keeps you POS‑ready for Sunrise 2027 while also staying aligned with evolving hemp‑THC labeling expectations across the U.S. (Informational only; not legal advice.)

What “Sunrise 2027” actually means for beverage brands

GS1’s Sunrise is not a single federal law or a single retailer mandate. It’s an industry alignment target driven by GS1 members across retail, CPG, healthcare, and solution providers.

At a practical level, Sunrise 2027 is pushing the market toward:

2D barcodes that scan reliably at POS (speed, contrast, quiet zones, error correction, print tolerances)
Standards-based data carried in the barcode so systems can interpret it consistently
Dual-purpose codes that can work both as an identifier for checkout and as a gateway to digital content for consumers, trading partners, and regulators

In 2025, retailer pilots and technology refresh cycles are accelerating because:

Many retailers are upgrading scanners and POS software now, not in late 2026.
Some retailers want to consolidate multiple codes (UPC + marketing QR + other QR) into one standards-compliant 2D that is easier to govern.

Key business implication

If you wait until 2026 to begin, you may end up:

Rebuilding label artwork twice
Re‑issuing item setup data repeatedly
Migrating link infrastructure under pressure (which is when recall workflows tend to fail)

Marketing QR vs. GS1 Digital Link: the difference that matters at checkout

A common misconception is: “We already have a QR code on pack.” For Sunrise 2027 readiness, that’s not enough.

Marketing QR codes (typical)

A marketing QR often encodes a single URL, such as:

https://brand.com/product/blue-raspberry

This can be useful for campaigns, but it’s not a consistent product identifier and doesn’t tell a retailer system what the item is. It also typically lacks:

A globally unique trade item identifier
A standardized way to include lot/batch or expiration date
Structured attributes that can drive recall targeting

GS1 Digital Link QR codes (standards‑compliant)

A GS1 Digital Link QR code encodes a URL that contains GS1 identifiers in a standardized syntax so many systems can interpret the same scan.

A simplified example structure looks like:

https://id.gs1.org/01/00012345678905

Where 01 is the GS1 Application Identifier indicating a GTIN, and the following digits represent the GTIN.

It can also include key attributes commonly needed for quality and safety workflows, such as:

10 for lot/batch
17 for expiration date
21 for serial number (where applicable)

That means a single 2D can support:

POS price lookup (via the GTIN)
Targeted recalls (via lot/expiration)
Consumer transparency (via resolvable links to product info, COAs, usage guidance)

Why retailers prefer GS1 Digital Link for “one code” strategies

Retailers and their solution providers increasingly want:

A consistent primary key (GTIN)
The ability to route to retailer-specific endpoints without printing multiple codes
A path to richer data without breaking checkout

GS1 Digital Link supports this by allowing “one code” that can resolve differently depending on context (consumer scan vs. retailer app scan vs. internal quality scan), while the embedded identifiers remain standard.

External reference: GS1 US overview of the Sunrise initiative and 2D barcodes (start here): https://www.gs1us.org/industries/retail-grocery/2d-barcodes

Hemp‑THC beverage labeling reality: you may already be “QR‑required”

Hemp‑THC beverage requirements are not unified federally. They vary by state and change quickly. Still, several states that explicitly regulate hemp‑derived cannabinoid products have moved toward requiring that consumers can access lab testing information.

Common patterns businesses are encountering in 2024–2026 rulemaking and guidance include:

A label must provide access to a COA (often via a QR code or URL)
The COA must match the lot/batch and the finished product package
Product labels must include potency per serving and per package, ingredient statements, warnings, and sometimes age-related restrictions

The compliance risk: if you print a separate “COA QR” that points to a PDF without governance, you can end up with:

Broken links after a website migration
COAs that don’t match the lot in market
Multiple QR codes competing for scan priority, confusing both consumers and retailers

The goal: one standards‑based 2D code, multiple compliance outcomes

For hemp‑THC beverages targeting grocery/c‑store distribution, the pragmatic 2025 goal is:

Use one primary 2D barcode that is GS1 Digital Link and POS-capable
Route consumer scans to a product page with COA access and required disclosures
Route trade/regulator scans (or authenticated scans) to recall, traceability, and lot verification endpoints

This reduces label clutter and creates a single governed identifier for product transparency.

How to harmonize with state-required COA/traceability QR expectations

Many compliance programs expect the QR to take a consumer to testing results quickly. You can meet that expectation with GS1 Digital Link by:

Embedding the GTIN in the link so you always know “what product”
Including the lot in the link so you always know “which batch”
Having the resolver route to the correct COA for that lot

Important operational nuance: COAs are often issued per batch/lot. If your QR code is static and points to a generic “COA library,” it may satisfy a basic expectation but creates mismatch risk. A lot-aware Digital Link strategy is more recall-ready.

2025 readiness signals: what brands should watch

Even without naming specific chain mandates, the 2025 signals coming from GS1 forums and retailer technology roadmaps are consistent:

Retailer pilots are focusing on scan performance at POS and item file alignment
Solution providers are preparing for dual symbology periods (UPC/EAN plus 2D) during migration
Brands are being asked to improve data quality and digital product content

If you’re selling hemp‑THC beverages, your additional signal is the speed at which states add packaging and testing transparency requirements. Building your link and data governance in 2025 helps you adapt without reprinting everything.

The 2025 punch list: build a Sunrise‑ready labeling and data program

Below is a practical implementation checklist designed for beverage brands and co-packers.

1) Confirm your identifier strategy: GTIN discipline is non‑negotiable

To participate in standards-based scanning:

Assign a unique GTIN to each retail trade item (each flavor/size/pack configuration)
Maintain GTIN change rules when net contents, formulation, or claims change
Align your GTINs with your item setup and distributor catalogs

Takeaway: A perfect QR code won’t fix messy item identity. Start with the GTIN.

2) Choose the right 2D symbology and placement for beverages

Most Sunrise strategies use either:

GS1 QR Code (QR with GS1 data and Digital Link), or
GS1 DataMatrix (common in healthcare and some retail contexts)

For beverages, QR is frequently preferred for consumer engagement, but you must still design for:

Reliable scanning on curved surfaces (cans)
Condensation and abrasion
Minimum size and contrast requirements

Work with your printer and packaging engineer early. Changing varnish, ink density, or can curvature can materially impact scan rates.

3) Design a GS1 Digital Link that can carry lot/expiry when you’re ready

Even if you don’t print variable lot information in 2025, design your architecture to support it.

A mature path looks like:

Phase 1 (2025): GTIN-only Digital Link to a governed product page
Phase 2 (2026): Add lot (and optionally expiry) in the encoded data, supported by packaging line variable printing
Phase 3 (2027): Use lot/expiry to drive targeted recall and quality workflows automatically

4) Build link management like a regulated system (because it becomes one)

Treat Digital Link as regulated infrastructure, not a marketing microsite.

Minimum controls to implement in 2025:

Link resolver strategy (GS1 domain, brand domain with GS1-compliant paths, or a resolver provider)
Uptime and monitoring (broken links become a compliance issue)
Redirect governance (who can change destinations, approvals, audit logs)
Versioning (what happens when formulas or COAs update)

5) Define your data model: what must be true for every SKU and every lot

To support POS, recall, and transparency, define a canonical dataset that includes:

GTIN, brand name, product description, net contents
Serving size and potency disclosures (as applicable)
Ingredients and allergens
Manufacturing site/co‑packer identifiers (internal)
Lot/batch and production date (where applicable)
COA document pointer and lab metadata
Regulatory warnings and jurisdiction-specific statements

Avoid “PDF-only compliance.” Make your product data queryable so you can respond quickly during an enforcement inquiry or retailer audit.

6) Create an age‑gate workflow that doesn’t break access to required info

Many hemp‑THC beverage programs use some form of age restriction messaging. If you implement an age gate on the consumer destination page:

Ensure required safety/testing information remains accessible as needed
Don’t block recall notices behind a gate
Document the business rule (who must see what, and when)

A common pattern is:

Allow COA access and recall notices without friction
Gate marketing content, store locators, or promotional engagement

7) Build recall readiness into the 2D experience (not as a separate plan)

A recall-ready Digital Link program includes:

The ability to publish a recall notice immediately for a GTIN/lot
A workflow that updates the consumer landing page and a trade endpoint simultaneously
Internal triggers from QA to digital team with defined SLAs

If you can’t change the destination quickly and audibly during an event, the 2D code becomes a liability.

External reference on product identification and recall concepts (GS1): https://www.gs1.org/standards/barcodes/2d

8) Coordinate co‑packers and line capabilities for variable data printing

Lot-aware 2D codes often require:

Inline inkjet/laser printing capable of encoding variable data
QA verification scanners on the line
Procedures for rework and scrap (bad codes must not ship)

Put this in co‑packing agreements now:

Who owns the code specification
Who validates scan quality
What happens when a batch is relabeled

9) Plan for the “dual barcode” transition without confusing retailers

Many brands will run with both a UPC/EAN and a 2D code for a period.

Key controls:

Avoid printing multiple QR codes that look similar
Ensure the 2D is clearly intended as the primary “scan me” code for information, while UPC remains for legacy POS if needed
Align with retailer item setup instructions (some will specify which symbol is primary during pilots)

10) Document change control and compliance evidence

Treat your labeling and link program like a compliance system:

Maintain SOPs for link updates, COA posting, and lot mapping
Keep evidence of QA checks for barcode grade/scan tests
Archive COAs by lot and tie them to distribution records

This documentation is often what enforcement agencies, retailers, and insurers ask for when there’s a complaint or adverse event.

How this intersects with broader U.S. traceability trends

Even though the hemp‑THC beverage landscape is not governed by a single unified federal product framework, the broader U.S. supply chain is moving toward stronger traceability and faster recalls.

If your organization sells into mainstream channels, your buyers will increasingly expect:

Standard identifiers (GTIN)
Lot-level traceability capability
Rapid consumer notification options

A GS1 Digital Link 2D strategy is a practical way to align with those expectations while keeping your label footprint under control.

Practical takeaways for 2025

If you do only five things this year, do these:

Get GTIN assignment and item setup discipline in order.
Pick a GS1 Digital Link approach (domain, resolver, governance).
Build a product/lot data model that can power COAs and recalls.
Align packaging and co‑packers on print quality and variable data capability.
Create a tested “recall landing page” workflow connected to the 2D code.

For consumers: what will change by 2027

As 2D codes become common at checkout, consumers will likely see:

Fewer competing codes on packaging
Faster access to batch-specific testing documentation when provided
More consistent product information across retailers and brands

The key is that the code on pack becomes a trusted pointer—not an ad hoc marketing link.

Stay current (and keep your rollout compliant)

Sunrise 2027 is a catalyst, but hemp‑THC beverage requirements are still evolving state by state. The brands that win shelf space will be the ones that treat cannabis compliance, labeling, and digital identity as a single system—not separate tasks owned by different teams.

To track state-by-state labeling rules, COA access expectations, and upcoming changes—and to build a defensible compliance workflow around GS1 Digital Link—use https://cannabisregulations.ai/ for ongoing compliance support, monitoring, and implementation guidance.