Live at GS1: Why Sunrise 2027, 2D Barcodes, Won't be Optional for Brands
At GS1 Connect, Dillard’s CTO Chuck Lasley intimated that Sunrise 2027 and the move to 2D barcodes won't be optional for brand. Even though they don't sell in Dillard's, brands like Unilever and P&G know the time to rethink on-pack data strategy—for compliance with retail mandates and competitive edge—is now. Dillard's won't be the only retailer asking for this; Walmart and Wegmans are likely to, as well.
As demonstrated in garment tags, but applicable to on-pack or on-label messaging, this transition is a likely path for 2D barcodes adoption as part of Sunrise 2027.
GS1 Connect shared slides
Sunrise 2027 is an industry-wide initiative led by GS1 US to transition from traditional 1D barcodes (like the UPC) to 2D barcodes (such as QR codes or Data Matrix), which are capable of holding much more data. These 2D codes can carry dynamic, serialized, and contextual information—including GTINs, expiration dates, batch/lot numbers, and URLs—while still being scannable at retail point-of-sale (POS) checkouts. This shift will enable better inventory control, traceability, recall management, consumer engagement, and more. For food, beverage, and CPG brands, the implications extend beyond checkout: 2D barcodes will transform packaging into a smarter data carrier, connecting physical products with digital intelligence.
Mandates, by Any Other Name A central question among brand owners has been whether 2D barcodes will be required or voluntary. Chuck Lasley, CTO at Dillard’s, answered this clearly at GS1 US's Amplify event: “We’re going to give you a minimum requirement. But what you choose to add, in addition to that, is entirely up to you.” Those minimums? At the very least, a GTIN, a serial number, and ideally a brand URL. These data elements must be encoded to the GS1 Digital Link standard—a standardized, machine-readable way of packing structured data into a 2D code.GS1 Data Matrix Code encoding guide with AI breakdown and sample barcode, demonstrating the types of data Dillard's would like to see. Depending on the product, lots of other data varieties can be incoded. For CPGs, that includes expiration dates, batch and best buy codes, and supply chain data -- potentially even packaging material for identification downstream upon recovery at MRFs, assuming it can be read by scanning equipment in its state of disposal. GS1 Connect shared slides
While Dillard’s isn’t a grocery retailer, Packaging World editors see the broader industry reality: 2D barcodes may not be legislated mandates, but they will function as such through retail compliance requirements, whether Dillard's or grocery retailers who deal with faster-moving consumer goods. As soon as a major retailer requires them for shelf space, brands will need to comply—or risk losing distribution.
UPDATE: In another panel discussion today, a day after the conversation with Lasley, Paul Wawrzyniak at Wegmans Food Markets had this to say on possible 2D barcode mandates.
When asked: "Has Wegmans set a compliance date for having 2D barcodes for its [brand owner] suppliers?
He answered: "We have not formally notified our suppliers on that. We are discussing and talking about a letter to go out, and the wording of that. It's two things: [First]... confirming knowledge that this is coming. Part of our challenge is communicating and explaining the value statements of this and why manufacturer suppliers will want to embrace this and add it to their products. [Second]... there are hundreds of application indicators. And we encourage all [brands] go through that list. Don't just look for the few that you think you're going to use. Review them all and then and challenge and ask, 'why is that even an indicator that's available?' As we go through the product line, whether you're manufacturing it, if it's CPG items in the center store, or dry goods, there may be a different set that's applicable, but they're all value added. As a retailer, we want to hear back on which are the ones you're selecting, and we want to share the ones that we believe are high value to us..."
The collaboration in deciding which identifiers to use is important, as 2D barcodes can only occupy so much label space, and they can only be so dense before losing scan-ability. Given these constraints, brands and their retail partners must prioritize together which suite of identifiers is optimal, delivering the highest values for all parties.
The Transition Period: Labels in Flux Lasley presented an image of transitional tags showing three phases: (1) a traditional 1D barcode only, (2) both 1D and 2D barcodes on the same hang tag, and (3) a future state with just a 2D code. During the transition, both barcodes will be needed—but placement matters. “If you have too much separation between those barcodes,” he warned, “you may read that as two separate items… double ring that item.” GS1 recommends placing both codes within 50 millimeters to prevent such errors, especially in high-speed grocery environments.
From Redundant to Efficient Lasley shared that he scanned one product hang tag with six data carriers on it: two UPCs, two QR codes, a data matrix, and an RFID tag. “I think we can probably reduce that,” he joked. His vision: consolidate to a single 2D code (for digital content and traceability) and, if needed, a complementary RFID tag.
Unlike RFID, which adds a per-unit cost, 2D barcodes consolidate data needs and consumer engagement features without additional hardware. For brands using multiple stickers or on-pack labels (e.g., one for the UPC, another for product info, and yet another for a marketing QR code), 2D represents an opportunity to simplify packaging, reduce clutter, and cut material costs.
What (Dillard's) Vendor Brands Should Encode Lasley was explicit about what Dillard’s wants in the 2D codes it receives, though the suite of requirements is likely to vary by product (i.e., food will need expiration data, personal care products will need batch, etc.):
GTIN (01): for product identity
Serial number (21): for unit-level traceability, fraud prevention, and omni-channel data integrity
Brand-owned URL: for consumer experience, dynamic messaging (i.e., code stays static, but brand can change what's called up or redirected, over time), or recall visibility
He emphasized that while the QR printed on pack is static, the URL it links to can be dynamic. This allows the brand to update messaging, show new videos, trigger location-based offers, or issue recall instructions—after the item has shipped, stocked on shelf, or purchased.
Lessons Learned: Get It Right the First Time Lasley shared a cautionary tale: his team encoded their own private-label items with a 13-digit GTIN instead of the required 14 digits. Their own point-of-sale system rejected the products. “We kicked out our own merchandise,” he admitted. The lesson: test early, test often, and don’t assume tag providers understand GS1 standards without explicit direction.
CPG-Specific Guidance While Dillard’s focus is apparel, Lasley’s insights are highly relevant for CPGs. Food and beverage brands face even faster POS environments, shorter shelf lives, and more complex regulatory requirements. By embedding additional fields like expiration date (AI 17) and batch/lot (AI 10), brands can:
Enable real-time traceability for recalls
Drive replenishment intelligence
Build trust with consumers via transparency
Brands should also test POS systems for double scans and validate scanner behavior in grocery lanes. Sunrise 2027: The evolution of 1D GTIN barcodes to 2D data carriers, scanable and readable, unlocks the internet on labels.
Don’t Wait for the Letter Lasley made a final, essential point: “If you’re doing it just because we sent you a [mandate] letter, you’re missing the boat.” He urged brands to think bigger: about supply chain optimization, loss prevention, personalization, and more. “That’s the competitive advantage,” he said. “That’s what you’re going to have to figure out that makes your company better by using this technology.”
For brands in food, beverage, personal care, and household goods, Sunrise 2027 isn’t just a barcode update—it’s a new digital foundation. Those who approach it as a packaging challenge will be compliant. But those who see it as a brand strategy will be ahead of the curve.
FDA warning letters surge - is your team prepared?
New guide reveals expert strategies to prevent regulatory issues and respond effectively to FDA enforcement actions in pharmaceutical and medical device manufacturing.
Looking for CPG-focused digital transformation solutions? Download our editor-curated list from PACK EXPO featuring top companies offering warehouse management, ERP, digital twin, and MES software with supply chain visibility and analytics capabilities—all tailored specifically for CPG operations.