Anyone can generate a QR code themselves in a few minutes using free software. However, for the digital product passport for furniture, it is not about the code itself, but about what lies behind it: the code must remain permanently readable, must point to current and accurate data, and that reference must comply with the technical requirements set out in the regulation and the associated delegated acts. These requirements are not yet fully developed at the time of writing; the delegated act for furniture is currently expected in 2028, and the obligation itself around 2030. As soon as the text is final, we will publish the precise requirements.
Whether you can create the code yourself therefore does not depend on your technical skills but on what must continue to exist behind that code: a dataset that is accessible, current and traceable for ten years. This is the component where most companies run into difficulties, not the creation of the image.
What the data carrier must actually do
The QR code, or a comparable data carrier, is the key to the passport. It appears on the furniture, on the packaging or in the accompanying documentation, and points to a page or file containing information about that specific product or product group. The regulation sets requirements for the underlying data: they must remain current, they must be accessible to the parties entitled to access them, and they must be available for consultation throughout the entire lifespan of the furniture. A QR code that points to a dead link after a few years does not meet that purpose, regardless of who created the code.
This means that the question "can I do this myself" is actually two questions. The first is technical: can I generate a QR code and have it applied to my products? That question can be answered yes for virtually every business. The second question is organisational: can I guarantee that the data behind it remains correct, up-to-date and accessible for ten years, even if my company switches software providers, moves a website, or ceases to exist? For most SMEs, that question is considerably more difficult to answer.
What you can reasonably arrange yourself
Companies with their own IT department or a stable, long-term relationship with a software supplier can set up part of the process themselves: collecting product data, structuring it, and linking it to a central database. Creating the code itself and applying it to the product or packaging can also be done well in-house with the right instructions. For those starting with this, it is advisable to map out in advance which data is already available and which is still missing; that overview will save a lot of work later. In the knowledge base with explanation per subject are the points where companies often run into difficulties.
What is more difficult to organise yourself is continuity over a period of ten years. A QR code that today points to a page on your own server must also work if that server is replaced, if your company changes name, or if you transfer operations to a successor. This requires a form of hosting and management that is separate from day-to-day operations, and that is precisely the point where many companies decide to outsource part of it.
Where the line between doing it yourself and outsourcing lies
The boundary is not about QR code technology, but about the duration and reliability of what lies behind it. Doing it yourself is defensible for collecting and providing source data: no one knows your products better than you or your supplier. Outsourcing becomes more attractive as it comes to long-term hosting, keeping up with changes in technical requirements, and ensuring that the code still points to valid information after ten years, even if there is no longer anyone internally who knows how it was set up.
What a software vendor or service provider adds
A vendor that compiles and hosts the passport for you takes on three things in practice: technical safeguarding of the data carrier, continuity over the full duration, and keeping up with changes in regulations once those become final. Before you make that choice, it is useful to know what questions you can ask a software vendor and how you see where the data in such a passport comes from. This way, the choice between doing it yourself and outsourcing remains a conscious decision rather than a guess.
What happens if the data carrier does not work properly
The regulation itself addresses the obligation to make a passport with a functioning data carrier available, not who technically hosts that passport. What happens if a QR code no longer works or points to outdated data is for the competent supervisory authority to assess; this article deliberately makes no statement on that. For your own situation, a lawyer or the supervisory authority is the appropriate party to consult.
Doing it yourself, having it done, or a middle ground
For most businesses, the practical route lies somewhere in between: providing product data yourself and keeping it current, and outsourcing the technical side of the data carrier and long-term hosting to a specialized party. Whether that makes sense for your business depends on the size of your range, your internal IT capacity, and the time you can free up for management over a period of ten years. A comparison of the costs of both routes can be found at prices and what is included for that.
Do you want to see what your own situation looks like first before you decide between doing it yourself and outsourcing? With the free quick scan of a few questions you get a first indication, without needing to create an account.