Digital fertilizer label 2027 – QR check, physical marking and 10-year archive | Word/PDF/Excel

Do you want to use digital labelling for CE-marked fertiliser products from 1 May 2027? EU Regulation 2024/2516 amends the rules for EU fertiliser products under Regulation 2019/1009. Digital labelling will be possible within clear boundaries – but a QR code does not generally replace all physical labelling. With these templates, you document the chosen sales channel, the correct labelling information, available digital information, and ten-year archiving.

Who benefits from the package? Swedish manufacturers, importers, retailers, and distributors of CE-marked EU fertiliser products for agriculture and gardening. The package does not automatically cover nationally regulated fertilisers without CE status under EU 2019/1009. Product-specific PFC/CMC, CLP, and language requirements must be reviewed separately.

Current law: EU 2024/2516 – digital labelling of EU fertiliser products applies from 1 May 2027. It introduces Articles 11a, 11b, and 11c into EU 2019/1009. Digital labelling is a voluntary option where permitted by law, not a new general mandatory QR code requirement. The Commission's planned complementary technical rules must be followed when they are adopted.

Which labelling form applies to your specific sales?

Packaged for other economic operators – Article 11a.1: A physical or digital label can be used for the current link in the supply chain. When reselling to end users, the rules for the end-user link must be applied separately.

Unpackaged for economic operators – Article 11a.2: Digital label or accompanying physical delivery note.

Packaged for end users – Article 11a.3: Physical label or digital label where the required information is also reproduced physically. Only information specifically marked with an asterisk in Annex III may be omitted from physical duplication under certain conditions. Therefore, a QR code on the consumer package alone is generally not sufficient.

Unpackaged for end users – Article 11a.4: Digital label or delivery note. A digital option in a physical store requires visible labelling at the point of sale according to Article 11c.3.

Specific definition: Regulation 2024/2516 defines packaging as a closable container holding no more than 1,000 kg (Article 2.10a of the amended basic regulation). This must not be misinterpreted as meaning that larger quantities have no labelling requirements.

Six Checks for a Functional Digital Label

1. Complete content: manufacturer/importer, CE marking, where relevant the notified body ID and the information under Annex III, compiled and separated from advertising.
2. Direct access: free, without purchase, login, password, or app installation; functional in standard web browsers and operating systems.
3. Availability: searchable information, understandable language, adaptations for, for example, persons with visual impairments.
4. Data carrier: The QR code or other machine-readable carrier must actually lead directly to the correct product label and be visible and readable in the correct place.
5. Ten-year operation: labelling information must be available ten years after placing on the market, even in the event of business closure or insolvency.
6. Privacy and alternative methods: Article 11c limits the tracking of use and requires free information by other means upon request even without purchase; during temporary operational interruptions at the time of purchase, even without a request.

File List – Exactly What You Get

Excel Register with Nine Tabs

Overview, Products, Channels, Labelling Matrix, Digital Labels, QR & Test, Alternative Info, Actions, Sources & Guide. Eight formula-based metrics monitor the number of actually registered products, channels, labels, missing labelling information, failed test cases, open information cases, open actions, and internal batch blocks. All eight metrics have been tested with an empty register and a separate synthetic case. The delivered customer file contains zero actual cases.

How to Use the Document Package

1. Identify the CE fertiliser product and manufacturer/importer role; check current PFC/CMC.
2. Determine the sales channel and the correct branch of Article 11a.
3. Compare the physical label against the digital information, the correct Annex III, Swedish language requirements, and any CLP labelling.
4. Test the actual QR/URL flow, text, browser, availability, logging, and archive.
5. Create a functional free backup for the user, even during operational interruptions.
6. Track versions, responses, and test evidence; make separate manual decisions about actions and batches.

Frequently Asked Questions

Is QR labelling mandatory from 1 May 2027?

No. The regulation opens up the possibility of using a digital label within specified boundaries. A physical label can continue to be used.

Can a consumer bag be labelled with only a QR code?

No, not generally. For packaged sales to end users, mandatory information must be provided in physical form, with specific exceptions for asterisk-marked information.

What happens if the labelling website is down?

The product provider must be able to provide relevant labelling information in another way free of charge. During temporary unavailability at the time of purchase, the information must also be provided without the customer having to request it first.

What is required of a QR system?

The direct link must lead to the correct digital label. The information must be free, directly accessible without a password or app, searchable, and available long-term.

Must the information be available for ten years?

Yes, from the time the relevant EU fertiliser product was placed on the market, even if the business were to close. An actual operational and archiving plan is required.

Does this suit all fertilisers sold in Sweden?

No. The package concerns EU fertiliser products within the scope of (EU) 2019/1009. Nationally regulated fertilisers and separate CLP requirements must be handled according to their own regulations.

Will I receive a finished CE label or QR service?

No. These are editable templates and control registers, not a published labelling website, approved CE declaration, technical system, or actual products.

Are all documents in English?

No. The five operational documents and Excel are in Swedish; one Swedish and one separate English user guide are included.

Official Sources, Transparency, and Related

EU Regulation 2024/2516 · EU Fertiliser Product Regulation 2019/1009 · Swedish Chemicals Agency – EU Fertiliser Products · Swedish Board of Agriculture – Trade in Soil and Fertilisers.

Businesses that also need to document packaging requirements can see Mallbutikens separate PPWR Packaging Package. Packaging legislation and fertiliser product labelling are different regulatory areas.

Version 1.0 – AI-assisted source control 11 November 2026. No external legal review, technical review of an actual label, CE certification, regulatory review, or product registration has been performed. Check the current wording and future delegated acts before concrete use. The ZIP is not yet linked to Shopify Digital Products, and the product remains unpublished (DRAFT).