Where is the line between doing it yourself and outsourcing?
In principle, you can organize having a label with a QR code printed and affixed to a garment yourself. The regulation sets requirements for the data carrier (the QR code or comparable code) and for the content that the code points to, not for who physically produces or applies the label. What is fixed, however, is a number of technical and substantive conditions that the code must meet, and that is precisely the part where companies encounter practical limits.
The shortest way to put it: affixing a label is a production activity, compiling and maintaining the passport is an information obligation. Both are part of the same process, but they require different expertise and different planning.
What the regulation specifies about the QR code itself
The data carrier must be durable and readable for the duration of the product's life, and must point to a unique passport per model or batch. This means that a system must exist somewhere that links each code to the correct, current dataset. Once you start generating codes yourself, you are also responsible for that link: which code belongs to which item, and how do you prevent two products from accidentally receiving the same code or a code pointing to outdated information?
This may seem straightforward with a small collection, but becomes more difficult as variants, colours, sizes or reprints are added. Supervisory authorities will look at whether the code does what it is supposed to do: someone who scans it must reach a matching and current passport. How you organize that is up to you.
What you can organize yourself
The design of the label, the type of material, the placement on the garment and the choice of a print or sticker supplier: these are choices that are entirely up to you. There is no prescribed form for the label itself, as long as the code remains legible and scannable and does not come off or become unreadable through washing or wearing.
The timing of application, during production or only during packaging, is also a logistical choice. Many companies combine this with existing processes around care instructions or price tags, because a label workflow already exists for those. how other topics from the regulation relate to each other provides an overview of what else comes together in such a process.
What requires long-term responsibility
The more difficult part is not in the label, but in what is behind it. The passport must remain accessible for a longer period, even if a supplier ceases operations, a collection is withdrawn from the market or your company switches software packages. This requires a form of hosting that is not dependent on the lifespan of a single webshop or a single internal server.
Furthermore, the content of the passport must remain current if something changes, for example a new supplier for the same model. If you organize this yourself, you must not only be able to generate a code now, but also be able to demonstrate over years that the code points to the correct, updated information. This is the point where many companies decide between building a system themselves and outsourcing that part to a party that has it as a core activity. how such a link between code and data is set up in practice shows which steps are involved.
Whether doing it yourself makes sense for your situation depends on the size of your assortment, how often data changes and whether you already have a system that can preserve and provide access to data long-term. This is an assessment that differs per company and which the text of the regulation itself or a lawyer can clarify further for your specific situation.
In short
Printing and applying the label is a choice you can make and execute yourself. The link between that code and a passport that remains accurate and accessible for years is the part that requires the most preparation. If you would first like to see what that looks like for your products, then the free quick-scan answers a few questions with an initial indication of where you stand, and answers the overview of frequently asked questions the most frequently asked practical questions about the data carrier.