When the Top 300 QR code rule came into force in August 2023, most pharma companies treated it as a labelling change: add a code to the strip, link it to a product page, move on. Three years later, two things have changed. The requirement now extends far beyond 300 brands — to every vaccine, antimicrobial, anticancer and NDPS drug from 2027. And it's become clear that how a brand chooses to implement the code decides whether it does anything to stop counterfeits at all.
This is a practical checklist for brand owners: what the rule actually requires, what it leaves open, and the decisions that determine whether your QR code is just compliant or actually protective.
What the Rule Actually Requires
The requirement comes from G.S.R. 823(E), dated 17 November 2022, which added Schedule H2 to the Drugs Rules, 1945. CDSCO's July 2023 FAQs clarify how it applies. In short:
- Who: manufacturers of the brands listed in Schedule H2 — Indian and foreign alike, for products marketed in India.
- From when: every batch manufactured on or after 1 August 2023.
- What: a Bar Code or QR Code on the label.
- Where: on the primary pack label, or on the secondary pack label if the primary doesn't have enough space.
- Which data: a unique product identification code; proper and generic name; brand name; name and address of the manufacturer; batch number; date of manufacture; date of expiry; and manufacturing licence number.
- Imports: preferably coded before arrival; otherwise the code can be affixed after customs clearance, with permission from the Licensing Authority.
The unique product identification code is assigned by the manufacturer under its own Standard Operating Procedure. Brands not on the list may add codes voluntarily.
What the Rule Leaves Open
Just as important is what the rule and the FAQs don't specify. These gaps are where implementation choices — and their consequences — come in.
- Unit or batch? Nothing says every pack must carry a different code. A code that's identical across a whole batch can meet the text of the rule.
- Which standard? The rule doesn't name GS1, a symbology, or a data format.
- What happens on scan? There is no central government verification database and no prescribed scan experience for the patient.
- Who verifies? There is no mandated scan event at the distributor or pharmacy.
Batch-Level vs Unit-Level: The Decision That Matters Most
The cheapest way to comply is a batch-level code: one QR per batch, printed identically on every pack, opening a page with the product details. It satisfies the data requirement. But because every pack in the batch carries the same code, a counterfeiter who buys one genuine strip can copy the code onto thousands of fakes — and every one of them will scan as "genuine."
| Question | Batch-level QR | Unit-level, authenticated QR |
|---|---|---|
| Meets the H2 data requirement? | Yes | Yes |
| Same code on every pack in the batch? | Yes | No — every pack is unique |
| Can a copied code be detected? | No — copies scan as valid | Yes — repeated or unsigned codes are flagged |
| Shows where a pack was scanned? | Only at batch level | Per pack, with location and time |
| Supports diversion detection? | No | Yes — a pack can be checked against its intended territory or channel |
| Printing requirement | Same code per batch | Variable code per pack, printed on the line |
The Compliance Checklist
The 2027 Timeline Is Closer Than It Looks
July 2027 sounds far away, but packaging changes move slowly. Artwork revisions, regulatory approvals for label changes, coder installation, line validation and supplier coordination can each take months — and Table 2 will hit many SKUs across many sites at the same time. Brands that start their SKU mapping and coding decisions in 2026 will have room to do it properly; brands that start in mid-2027 will be choosing whatever is fastest.
Where Ratifye Fits
Ratifye generates GS1-compliant QR codes that carry the full Schedule H2 data set, with a unique, cryptographically signed code on every pack. A scan confirms that the specific pack is genuine in under 80 milliseconds, and flags copied or unsigned codes instantly. It works with the coders already on your lines — no new hardware — and most teams go live in about two weeks, so the same project that delivers H2 compliance also delivers real counterfeit and diversion protection.
Compliant is the minimum. Make your QR code protective.
Ratifye's team can map your portfolio against Schedule H2 Tables 1 and 2 and show what a unit-level, authenticated rollout looks like on your lines. Start with 500 free authentications.
Talk to our regulatory teamSources: CDSCO notification G.S.R. 823(E) dated 17 November 2022 inserting Schedule H2 in the Drugs Rules, 1945; CDSCO FAQs on Bar Code / QR Code implementation for Schedule H2 brands (July 2023); G.S.R. 506(E) dated 22 June 2026 (Drugs (Seventh Amendment) Rules, 2026) inserting Table 2 in Schedule H2, following draft G.S.R. 757(E) of October 2025 and DTAB recommendations. This article is a practical summary; consult the primary regulatory texts and legal counsel for compliance decisions specific to your products.