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Sunrise 2027, Amazon’s Transparency Program Rewrite Product Packaging Rules

How 2D barcodes are giving CPGs a powerful edge in brand protection, supply chain visibility, and e-commerce integrity.

Nick Viskovich (left) and Michael Manley (center) of Amazon detail how on-pack 2D barcodes underpin anti-counterfeiting and validation efforts used by the company’s Transparency initiative in a panel moderated by GS1 US’s Andrew Moorhead (right).
Nick Viskovich (left) and Michael Manley (center) of Amazon detail how on-pack 2D barcodes underpin anti-counterfeiting and validation efforts used by the company’s Transparency initiative in a panel moderated by GS1 US’s Andrew Moorhead (right).

The countdown to Sunrise 2027 is on. By that date, a new standard is expected to take hold in retail and ecommerce environments: the 2D barcode will replace the traditional 1D UPC on product packaging. But for brands selling on Amazon—and increasingly across other retail channels—the future is already here.

Amazon’s Transparency program, which requires brands to apply serialized 2D Data Matrix codes to their products, is helping brand owners do much more than just comply. It’s helping them combat counterfeiting, prevent grey market activity, reduce retail theft, and build deeper consumer trust—all through smart packaging.

“This creates tremendous off-Amazon value, and we get to do Transparency,” said Michael Manley, Global Head of Technical Business Development at Amazon. “So it's a win, win all the way across the supply chain. Now it's a serial number that can be used for parent/child and all of the track and trace use cases… You talk about this vision of track and trace—how do you do it? Where do you start? This is where you start.”

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The mechanics of Transparency

At its core, Amazon Transparency is a proactive anti-counterfeit system. It requires brand owners—who must first be enrolled in Amazon’s Brand Registry—to assign a GTIN (Global Trade Item Number) to their products. Amazon then generates a unique, 26-character alphanumeric serial number for each item, which must be physically applied to the product using a 2D Data Matrix code.

Amazon scans every unit at outbound, whether it’s shipped from an Amazon Fulfillment Center (FC) or through a third-party via the Merchant Fulfilled Network (MFN). “If [a code] is not matching the description, and there’s no serial number associated, it will be sidelined, investigated, and destroyed,” explained Nick Viskovich, Global Head of Sales, Consumer Electronics for Amazon. “It will never make it to a customer.”

For packaging and operations teams, the central question becomes: how do you apply serialized 2D codes at scale? Amazon offers three models:

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