Distribution code for COVID related distributions

If an IRA or QP participant is under 59 1/2 and takes a COVID distribution.  Should the trustee report on 1099-R distribution code 1 or 2?

Below, Section 3, A. of Notice 2020-50:

A. Tax reporting on coronavirus-related distributions An eligible retirement plan must report the payment of a coronavirus related distribution to a qualified individual on Form 1099-R, Distributions from Pensions, Annuities, Retirement or Profit-Sharing Plans, IRAs, Insurance Contracts, etc. This reporting is required even if the qualified individual recontributes the coronavirus-related distribution to the same eligible retirement plan in the same year. If a payor is treating the payment as a coronavirus-related distribution and no other appropriate code applies, the payor is permitted to use distribution code 2 (early distribution, exception applies) in box 7 of Form 1099-R. However, a payor also is permitted to use distribution code 1 (early distribution, no known exception) in box 7 of Form 1099-R.

Just to add on to Luke's answer, the code used (1 or 2) for the 1099-R really doesn't matter.  Filing Form 8915-E is what will signal "no early distribution penalty" to the IRS.