For wines produced from 8 December 2023 and sold in the EU, Regulation (EU) 2021/2117 requires a list of ingredients and a nutrition declaration. The energy value and allergens must appear on the physical label; the full ingredient list and nutrition declaration can be given electronically through an e-label reached by a QR code, provided that page carries no marketing content and does not track users. For the printer, the critical point is a QR code that scans reliably on textured paper, near foil and on a curved bottle.
- Energy value per 100 ml (which may be shown with the symbol E) and allergens stay on the bottle.
- Ingredients and full nutrition can move to an e-label via QR code.
- The e-label must not contain marketing or collect personal data.
- Each wine and vintage may need its own QR code: plan versions and variable data.
- Never print the QR code in foil or over texture; test scanning on the finished bottle.
What goes on the bottle and what can go online
| Information | Physical label | E-label via QR code |
|---|---|---|
| Energy value per 100 ml | Required | Can be repeated |
| Allergens (e.g. sulphites) | Required | Can be repeated |
| Full list of ingredients | Optional | Allowed instead of the physical label |
| Full nutrition declaration | Optional | Allowed instead of the physical label |
| Usual mandatory particulars (category, alcohol, provenance, bottler, lot, volume) | Required | Not a substitute |
| Marketing content | As usual | Not allowed on the e-label page |
Rules for the e-label page
- It must show only the mandatory information, not sales or marketing content, and it must not be your general brand website.
- It must not collect or track user data.
- It must be available in a language easily understood by consumers in the countries where the wine is sold.
- The QR code on the label should be clearly identified as leading to ingredient and nutrition information; check the Commission guidance and your national rules for the accepted wording.
Printing a QR code that scans on a premium label
| Risk | Why it fails | What to do |
|---|---|---|
| QR in foil | Metallic reflections confuse phone cameras | Print the QR in dark ink on a light, flat area |
| QR on textured paper | Felt or embossed texture breaks the modules | Keep the QR on a smooth area or check the stock with your printer |
| Too small | Modules too small to resolve on a curved bottle | Agree a minimum size with the printer and test on the bottle |
| No quiet zone | The scanner cannot find the code's edges | Leave a clear margin around the code |
| Low contrast | Coloured or tinted backgrounds reduce readability | Dark code on a light background, never the reverse on dark stock without testing |
| Curvature | The code bends on narrow bottles | Place it on the widest part, oriented to minimise curvature |
Versions, vintages and variable data
Ingredients and nutrition values can change between wines and vintages, so a winery with several references may need a different QR code on each label. With digital printing, different codes, vintages and versions can be printed in the same job. If the link is the same and only the destination page changes, a single code can serve several vintages, but the content must remain correct for each bottle on the market. See variable-data labels and short-run wine labels.
Frequently asked questions
Which wines must carry ingredient and nutrition information?
Wines produced from 8 December 2023 and sold in the EU. Wines produced before that date can be sold until stocks run out.
Can the QR code replace the whole wine label?
No. Energy value, allergens and the usual mandatory particulars must stay on the physical label; only the full ingredient list and nutrition declaration can be provided electronically.
Can the e-label page link to my shop or brand website?
The e-label must not contain marketing or sales content and must not track users. Keep it separate from your brand website.
Can a QR code be printed in gold foil?
It is not recommended: metallic reflections make scanning unreliable. Print it in dark ink on a flat, light area and test it on the finished bottle.
- Regulation (EU) 2021/2117 — EUR-Lex
- Regulation (EU) No 1308/2013 (common market organisation), as amended — EUR-Lex
This guide summarises public sources for information. It is not legal advice: check the official text and your own regulatory advisers.