how do I get a QR code on a very small piece of steel

What you must concretely do

What is expected of you

A data carrier that remains readable over the product's lifespan

Article 11 of the ESPR (Regulation (EU) 2024/1781) requires a data carrier that is technically reliable and that matches the product as long as it is in circulation. For a small steel product — a bolt, a small plate, a profile a few centimetres long — that means in practice: there must be something on or with the product that a scanner or camera can read, and that continues to work after the product has been bent, galvanized, painted, or stored outdoors for years. For a company with 10 to 100 employees, this is primarily a production question: which marking technique (laser, dot peen, label, hang tag) fits the size and the process, and who on the shop floor is responsible for checking that the code remains readable after processing. More on the technical options is at how does the QR code for the product passport get onto my steel.

A unique link between code and product data

The data carrier itself is only useful if it points to the correct data of the correct specimen or the correct batch. That requires a system in which each code unambiguously leads to one product passport, without two products accidentally receiving the same reference. For smaller productions, it is practical to link this to an existing numbering system instead of building something new. How that works is at how do I assign a unique identification code to each product. With steel, there is also the question of whether the code is assigned per piece or per batch — something that does not have the same answer for every steel product, as described at do I register steel per batch or per unit.

A readable code, even if the surface does not cooperate

Article 16 of the ESPR concerns labels and the requirements for them, and Article 17 concerns preventing counterfeit or misleading labels. For a small or irregularly shaped steel product, the practical bottleneck is often simple: there is too little flat, clean surface to get a readable code on. That is not a legal question but a physical one — and the solution then often lies not in the product itself, but in the packaging, a label on a bundle, or a shared carrier for a batch of identical pieces. Which data standard is useful in this case depends on how the code will later be scanned by customers; see what is GS1 Digital Link and do I need it for the product passport.

Ensuring the code aligns with the rest of your administration

A QR code that references a passport is usually not a one-time action but a permanent part of a production process. For most metal companies, it is desirable that the code is created automatically alongside existing order lines or article numbers, rather than being a manual extra step. How that integrates with an ERP or inventory system is described at can I link the product passport to my ERP or inventory system.

Where things go wrong in practice

The code is applied too small or too close to an edge. With small profiles or bolts, there is literally little space. A laser-etched code that looks good on paper turns out not to be scannable on a curved or machined edge just a few millimetres wide.

The marking disappears during post-processing. Galvanizing, blasting, coating or passivation can damage or render a previously applied code illegible. When the marking step takes place before the final processing step, the code is sometimes simply no longer there when the product leaves the door.

One code is used for a collection of loose pieces. A bundle of small parts receives one QR code on the packaging, while the pieces continue separately through the chain. Once the packaging disappears, there is no longer a link between individual product and passport.

The chosen technology does not read at the customer's end. A code that works fine internally with a specific scanner turns out to be unreadable at the buyer's end with an ordinary smartphone — for example due to loss of contrast on a metal surface or due to a non-standard format.

No account is taken of what happens to the product after sale. When the product is re-cut, re-pressed or resold in smaller units, the original code is sometimes literally lost, without it being documented what should then happen to the passport.

What you can document

• A choice of marking technology per product group, with justification for why it is suitable for the material, the dimensions and further processing.
• A control step in the production process in which it is recorded that the code remains readable after the final processing, including who checks this and how often.
• An overview of which products receive a code per piece and which per batch, with the reason for that division.
• Agreements with suppliers or subcontractors about who applies the code when part of the processing is outsourced.
• A documented link between the internal article number and the code that references the passport, so that this remains traceable in your own administration.
• A saved test series of scanned codes on different surfaces and after different processing steps, as evidence that the chosen method works in practice.

For the broader question of how long this code and the underlying passport should remain available after delivery, a separate overview is available at how long must a product passport remain available. Anyone who wishes to document these agreements and choices in a fixed manner can make use of the templates available to subscribers.