Is GS1 Sunrise 2027 mandatory for CPG?

It's an industry-wide readiness target set by GS1, not mandated by federal law, but major retailers are aligning their systems to it. The 2D barcode requirement is coming either way, so brands that wait until the deadline will be doing packaging redesigns under pressure instead of on their own timeline. Most large retailers will be compliant by the deadline, while other smaller, regional stores will not. Some brands are choosing to add a 2D barcode with the UPC code, so both remain on packaging for some time before phasing out the UPC code entirely.

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