February 25, 2026

2D Barcodes for Cannabinoids: How GS1 Digital Link and ‘Sunrise 2027’ Are Forcing Label Redesign in 2026

2D Barcodes for Cannabinoids: How GS1 Digital Link and ‘Sunrise 2027’ Are Forcing Label Redesign in 2026

In 2026, packaging teams for edible and beverage brands are being pulled into a “redesign now” cycle—not because their products changed, but because retail scanning is changing.

The U.S. retail ecosystem is moving from 1D UPCs to 2D barcodes that can be scanned at checkout and also unlock rich, dynamic product data. GS1 US refers to the industry target as Sunrise 2027: the goal is that by the end of 2027, retailers’ point-of-sale (POS) systems can scan and process 2D barcodes (e.g., QR) in addition to (and eventually instead of) traditional UPCs. GS1 US has also published tools like the Barcode Capabilities Test Kit to help retailers and solution providers assess readiness for scanning and processing 2D symbols at POS.

For cannabinoid and hemp-derived brands, the timing matters. You’re uniquely exposed to:

  • Retailer expectations for fast COA retrieval and auditable product details
  • A higher probability of stop-sale events, formula changes, and regulatory updates
  • Consumer demand for “proof” (lab results, ingredient transparency, warnings) delivered instantly on mobile

Done right, a GS1 Digital Link strategy can replace the chaos of “random QR codes everywhere” with a single, standards-based 2D barcode that works across checkout, inventory, compliance, and consumer transparency.

This article is informational only and not legal advice.

Why “Sunrise 2027” is forcing 2026 packaging decisions

The reason 2026 matters is not because 2027 is tomorrow—it’s because packaging cycles are slow.

If you’re a beverage or edible brand, you may have:

  • Long lead times for cans, shrink sleeves, cartons, and printed films
  • Retail planograms and compliance reviews that lock packaging far ahead of launch
  • Multiple state-specific SKUs already straining label real estate

GS1 US describes Sunrise 2027 as an industry transition to ensure 2D barcodes can be scanned at retail POS by the end of 2027. During the transition, many brands will carry dual marking (a classic UPC plus a 2D barcode), then later converge to a single multipurpose 2D symbol as scanning capability becomes universal.

Primary sources:

What GS1 Digital Link enables (and why it’s different from “a QR code”)

A normal QR code typically encodes a plain URL (or arbitrary text). A GS1 Digital Link QR code encodes a structured URL that contains GS1 identifiers (like a GTIN) using a standardized syntax. That structure is the point: it lets scanners, apps, and backend systems interpret the same scan consistently.

GS1 frames this as a path to “one product, one barcode”—a single multipurpose code that can support retail checkout and also connect to digital content such as certifications, instructions for use, traceability data, and more.

Primary sources:

The “structured URL” concept in plain English

GS1 Digital Link uses path segments (and optionally query parameters) to express identifiers and attributes. Common pieces include:

  • (01) GTIN (Global Trade Item Number)
  • (10) batch/lot
  • (17) expiration date
  • (21) serial number (for item-level serialization)

A canonical example format looks like:

https://id.gs1.org/01/{gtin}/10/{lot}/17/{expiry}

You can use GS1’s identifier domain (id.gs1.org) or your own brand domain—what matters is the syntax and resolvability.

Why cannabinoid products are uniquely exposed in this transition

Many consumer products can treat the 2D migration as a “future retail tech upgrade.” Cannabinoid and hemp-derived products often can’t—because regulators, retailers, and platforms increasingly expect batch-level accountability and rapid access to lab results.

1) COA retrieval is becoming a de facto expectation—even when not mandated

Across the U.S., it’s common for retailers (and some state programs) to expect a consumer-facing way to access lab results.

At the same time, some regulators draw a bright line between required on-pack labeling and off-pack digital content.

For example, California’s Department of Cannabis Control (DCC) labeling checklist for manufactured products states that required “supplemental labeling must be affixed” and that “QR codes, websites, and other methods that separate the information from the product are not acceptable types of supplemental labeling.” In other words: a QR experience can be valuable, but it generally can’t replace required on-pack statements.

Primary source (California DCC labeling checklist PDF, revised June 2024):

2) Batch/lot traceability is operationally critical (and is now label-driven)

When a stop-sale or recall hits, speed matters:

  • Which SKUs?
  • Which lots?
  • Which retailers?
  • Which dates?

2D barcodes powered by GS1 can carry batch/lot and expiration data in a machine-readable way, enabling faster identification of impacted inventory.

GS1 US explicitly notes that 2D barcodes can include information like batch and lot numbers and expiration date, and can provide access to recall notices.

Primary source:

3) Fraud pressure: COA swapping, URL hijacking, and “QR chaos”

In higher-risk categories, brands face:

  • Counterfeit packaging with copied QR codes
  • Third-party resellers swapping COAs across batches
  • Multiple QR codes on-pack that lead to conflicting information

A GS1 Digital Link approach helps by standardizing the identifier (GTIN) and optionally including batch/lot attributes in the scan payload, which can reduce ambiguity and support more robust validation on the landing page.

The 2026 label redesign reality: you may need to print two codes (for now)

Many retailers are upgrading, but POS readiness is not uniform. The practical 2026 approach for many brands is:

  • Keep a 1D UPC for universal POS scanning
  • Add a 2D barcode (QR or DataMatrix) encoded with GS1 Digital Link

This is consistent with the broader Sunrise 2027 transition approach: dual marking in the interim, then consolidation later as retailers achieve full 2D processing.

If you want to validate scanner and system behavior, GS1’s retail test materials can help teams understand not just whether a barcode scans, but whether the data is processed correctly downstream.

Primary source:

A practical build plan for GS1 Digital Link in cannabinoid and hemp categories

Below is an implementation blueprint aligned to what typically breaks in real-world rollouts: identification strategy, variable data, secure COA linking, and governance.

Step 1: Choose your GTIN strategy (this is the foundation)

Before you generate a single 2D barcode, align internally on GTIN allocation:

  • Does each flavor/format/size get its own GTIN? (Usually yes.)
  • What changes force a new GTIN vs. a batch-level attribute? (E.g., formula, net contents, regulatory category changes.)
  • Who owns GTIN governance across co-manufacturers and brand partners?

If you get GTIN strategy wrong, your “one barcode” future becomes a multi-year cleanup.

Where to start:

Step 2: Decide what to encode in the 2D symbol (minimum viable + scalable)

For cannabinoid and hemp products, a common minimum viable payload is:

  • GTIN as the primary identifier

Then, when your operations are ready (or where it’s high value), add:

  • Lot/batch (AI (10))
  • Expiration/use-by (AI (17))
  • Optional serial (AI (21)) for item-level anti-fraud and tighter traceability

Be realistic: adding variable data means your print workflow must support dynamic 2D codes (and your QA must verify them).

Step 3: Design the resolver and landing experience (compliance-first)

A GS1 Digital Link scan usually routes through a resolver or your own web service that can:

  • Identify the product from the GTIN
  • Identify the batch from lot/expiry attributes
  • Return the right digital resource (COA, warnings, ingredients, recall status)

For regulated products, treat the landing page like an extension of your label. That means:

  • Keep claims consistent with what is permitted on-pack and in that state
  • Version content by jurisdiction when needed
  • Maintain an auditable history of what a given GTIN/lot resolved to at a given time

Step 4: Link to COAs securely (and reduce “COA fraud”)

A common mistake is linking QR codes to a static PDF in a public folder. That creates easy attack paths:

  • Anyone can share or reuse the link
  • PDFs can be swapped
  • Batch-level matching is hard

Better patterns (informational considerations):

  • Resolve by GTIN + lot and fetch the COA record server-side
  • Publish read-only COA views with integrity controls
  • Consider short-lived tokens or signed URLs if you must serve PDFs
  • Display key results on-page (human-readable) and link to the full report

You can also support a recall workflow by returning a “do not use / stop sale” status for specific lots while keeping the GTIN valid.

Step 5: Avoid privacy traps (scans are data)

A 2D barcode can become a tracking surface if you’re not careful.

Practical privacy-by-design moves:

  • Do not require unnecessary form fills to view COAs
  • Avoid collecting precise location/device identifiers unless you have a clear, disclosed purpose
  • Keep analytics aggregated and minimize retention
  • Provide a simple privacy notice on the landing page

Even if you’re not thinking “privacy law,” your retail partners and regulators may be.

Step 6: Build a content governance model (claims and enforcement risk)

Your QR landing page is marketing real estate—but it’s also compliance risk.

Two key realities:

1) Regulators may view linked content as part of your labeling/marketing depending on context.2) Health-related claims require proper substantiation standards in advertising.

The U.S. Federal Trade Commission (FTC) Health Products Compliance Guidance emphasizes that health benefit claims must be supported by competent and reliable scientific evidence.

Primary sources:

Also note: FDA warning letters in the CBD space have repeatedly focused on drug/disease claims</strong) made on websites and other marketing channels, reinforcing that “digital” content can trigger enforcement when it crosses into prohibited claims.

Example warning letter index (CBD Social, 2022):

Compliance benefits: why this isn’t just a retail trend

A well-implemented 2D barcode strategy can reduce compliance cost and risk.

Faster stop-sale response

When enforcement actions or internal quality holds happen, resolving by lot means you can:

  • Flag affected inventory immediately
  • Provide retailers and consumers a consistent “status” message
  • Reduce confusion from outdated PDFs and mislabeled batches

Less COA fraud and fewer mismatched documents

Encoding lot/batch into the barcode and enforcing matching server-side makes it harder for bad actors to present the wrong COA for a product.

Cleaner labels (fewer codes, fewer contradictions)

Instead of printing:

  • a marketing QR code
  • a COA QR code
  • a loyalty QR code

…you can converge to a single GS1 Digital Link barcode that supports multiple experiences while staying standards-aligned.

Operational checklist for 2026 packaging teams (what to decide this quarter)

If you’re making label decisions in 2026, prioritize these questions:

  • Do we have a GTIN assignment policy we can defend in audits and retailer onboarding?
  • Will our 2D barcode encode GTIN only, or GTIN + lot/expiry?
  • Can our printers/packers handle variable 2D symbols at line speed—and can we verify print quality?
  • Who owns the resolver and uptime (internal vs vendor)?
  • What is our COA publishing model (static PDF vs resolved record)?
  • What is our content governance to prevent impermissible claims on the landing page?
  • What is our privacy stance on scan analytics?

How CannabisRegulations.ai helps

GS1 Digital Link, 2D barcodes, COA access, and multi-state labeling are converging into a single reality: your packaging is becoming an interface. For cannabinoid and hemp products, that interface must satisfy both retail POS readiness and regulatory compliance.

Use https://www.cannabisregulations.ai/ to:

  • Monitor state-by-state packaging and labeling changes
  • Compare COA access expectations across jurisdictions and retailer channels
  • Build a compliance-aware content checklist for QR landing pages
  • Stress-test your rollout plan against fast-moving enforcement trends

If you’re redesigning labels in 2026, the best time to align barcode strategy, COA workflows, and claims governance is before you lock print plates.