The health QR code is an important attempt in China dueling with social mobility under COVID-19 epidemic. It is not only a digital technology, but also a legal system. From the perspective of organic law, this QR code is a typical example of government as a platform. The administrative agencies should enhance its inclusiveness and establish an organizational structure consistent with the whole- of-government approach. In the aspect of behavior law, the health code is an important application of automated administration. In consideration of the substantial impact the QR codes have on civil liberties, the algorithm behind should meet the dual requirements of interpretation and audit. In terms of data law, the health code is a crucial element of data management. To balance individual rights and public interests, it is urgent to establish unified, independent, and professional agencies for personal information protection, so that a dynamic balance at different stages of the data lifecycle could be achieved. As a measure taken on an emergency basis, the health code cannot be normalized. When the epidemic is greatly alleviated, the health code system must be free from mandatory but become a voluntary public service, and the related personal information should also be deleted or anonymized in time.