Infant Formula Already Has a Mandatory Date. Put It in the QR Code.

· 5 min read Infant Formula GS1 Digital Link Sunrise 2027 QR Codes Compliance

One category deserves its own article: infant formula.

In the United States it is the one food where federal rules require a date on every container, there to back the nutrient claims on the label. Canada goes the same direction, requiring an expiration date on infant formula and telling Canadians that food past its expiration date should not be bought, sold or eaten. Formula makers already live under a date mandate.

That changes the question for a formula brand planning its Sunrise 2027 transition. For most products, a date in the QR code is optional enrichment. For formula, your labeling law already requires this date; GS1 Digital Link is how it becomes enforceable. The question is not whether to include the date in your code. It is how quickly you can.

One guardrail up front: nothing here says a Digital Link is mandated. It is not. The date is mandated. The code is the carrier that lets a machine act on it.

What the rules actually say

United States. 21 CFR 107.20(c) requires the label of an infant formula to carry a “Use by” date, with the month and year chosen by the manufacturer. FDA explains the purpose in its consumer Q&A on infant formula: the date is required on each container, and until that date the formula will contain no less than the amount of each nutrient declared on the label. USDA’s food product dating guidance notes that, except for infant formula, product dating is not required by federal regulations.

Canada. Section B.25.057 of the Food and Drug Regulations lists “the expiration date of the human milk substitute” among the required label information. The CFIA’s guide to date labels lists infant formula among the foods that must carry an expiration date, and states that food “should not be bought, sold or eaten if the expiration date has passed.”

We are deliberately careful about the line between what the regulation text says (a date must be on the label) and what regulator guidance says about selling past it. If you are a formula brand, your regulatory team owns the precise reading for your products and markets.

Today, the date is enforced by whoever happens to look

The use-by date on a can of formula is checked by a stocker rotating shelves, a cashier who notices, or a parent reading the bottom of the can. Every one of those checks is manual, and every one can be missed.

With AI 17 (the GS1 expiration date) in the Digital Link, the check can happen at every scan: at receiving, at the shelf and at the lane, using nothing but the code itself. No database call, no network dependency, no judgment call. A product category where the stakes are infants is exactly where enforcement should not depend on someone noticing.

What AI 17 in the code changes

A formula can’s Digital Link looks like this:

https://id.closient.com/01/00012345678905/10/L2026-1842?17=270300

01 is the GTIN, 10 is the lot, and 17 is the expiration date as YYMMDD. GS1 allows 00 in the day position to mean “the end of that month”, which matches how formula dates are printed (month and year). The date rides in the query string because it is a data attribute rather than a key qualifier. Any scanner that reads the code can read the date without asking anyone.

That unlocks four things:

  • Offline lane enforcement. A mandatory sale block has to work when the store’s network does not. A locally parsed AI 17 is the only architecture that guarantees it. The register compares the date in the code to today’s date and stops the sale, with no lookup.
  • Receiving checks. A dock scan can reject or flag short-dated cases the moment they arrive.
  • Automatic pull lists. Shelf and backroom scans can produce the list of cans approaching their date, instead of relying on a walk down the aisle.
  • Consumer scan. A parent scanning the can at home sees whether it is within its date, in plain words.

The recall dimension

Formula is also a category with recurring high-profile recalls and intense retailer scrutiny. The 2022 shortage made date and lot handling a board-level topic for the whole industry.

That makes it a strong case for adding AI 10 (lot) beside the date. A recall scoped to named lots only helps if a machine can read the lot on the can in a parent’s cupboard. We walked through what that is worth in the 2026 lettuce recall, where everything needed to scope the recall was already printed on the bag, just not machine-readable. For formula, the technical reference is Lot-scoped recalls. If you serialize, the serial implies the lot and keeps the URI short even in this maximal case.

It fits on the can

GTIN plus a date plus a lot is a short payload on a short domain, which keeps the QR code comfortably within the retail point-of-sale size envelope. Data length, not preference, decides the symbol size; see QR code sizing for the numbers.

Where Closient fits

If you make infant formula, the work is the same as for any lot-managed product: encode 01, 10 and 17, and keep the resolver behind the code accurate. Closient generates the codes and runs the resolver, so a scan can return the validity of the can in front of the person scanning it. The full field-by-field reference is in our docs: Infant formula expiration dates.

Regulatory citations in this post were checked against the sources linked above on October 14, 2026. This is not legal advice.