Practical roadmap to EU wine labelling with QR codes

Wine E-Label Masterguide

This masterguide is written for wineries, bottlers and wine brands that want to comply with EU Regulation (EU) 2021/2117.
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Introduction

The European Union has implemented changes to its Common Agricultural Policy (CAP) that will affect wine labelling requirements for wines intended for sale and consumption within the E.U. As of December 8th, 2023, all wine bottles labelled and sold within the European Union, regardless of origin, must include new information, as specified in regulation (EU) 2021/2117 of the European Parliament and the Council.

This masterguide is written for wineries, bottlers and wine brands that want to comply with EU Regulation (EU) 2021/2117. You’ll learn which wines are affected, what must appear on your digital label, how QR codes should be implemented, and how to set up a simple process that works vintage after vintage. It is important to note that this collection does not constitute legal advice and may be subject to updates.

Which products fall under Regulation (EU) 2021/2117?

  • ✅ Own brands and private-label products bottled for others
  • ✅ Still, sparkling, aromatised wines and some related products
  • ✅ Wines produced and labelled after the relevant cut-off date
  • As a rule of thumb, all wines from the 2024 vintage onwards should be prepared to follow the new rules when they are placed on the EU market. Older stock may be treated differently, but most wineries choose to update labels as soon as they refresh packaging to avoid confusion.

    Producers should have the option of limiting the contents of the nutrition declaration on the package or on a label attached thereto to only the energy value and of making the full nutrition declaration and the list of ingredients available by electronic means

    What has changed for wine labelling in the EU?

    Now you will be able to create your e-Label, publish the information on QRFox.eu, test the QR code by scanning it and checking on the information.

    Mandatory information

    • Ingredient list, formatted according to EU rules
    • Nutritional declaration per 100 ml in kJ and kcal (also visible on physical label)

    The physical label on the wine bottle must continue to include the full list of allergens - in all languages, energy content, fill quantity, alcohol content, vintage, bottler, winery and product name.

    Optional information

    • Recycling information for the Italian market
    • Other generic information that is not connected to any kind of marketing or branding

    From bottle to browser: how e-labels work in practice

    1. QR code on the bottle
      Placed on the same field of vision as the required information and the text near the code clarifies its purpose (e.g. “Ingredients and nutritional values”)
    2. Dynamic and reliable QR code specific for each product
      The measured value should be within the tolerances around the declared value during the entire shelf life.
    3. Direct and user-friendly
      Has to directly open the requested information and the tracking of the users information in not allowed. The mandatory information must be written in a language that is easy for the consumer to understand.

    The first step is to make sure that all the information you need for your e-labels is verified and collected.

    For each wine, you should have:

    • Product name as it appears on the label
    • Ingredient list and allergen
    • Nutritional values per 100 ml (kJ, kcal, carbohydrates and sugar)
    • Target markets (which countries you sell this product to) with this information we can directly activate the translation in the right languages.

    Now you can create your e-label, publish it and test it. Share your QR code and the energy information with your printer. The following formats are availabel: JPEG, PNG, SVG (recommended) or PDF (recommended) and you're good to go.

    👉 Download the full checklist as a PDF

    Get a printable version with space for notes, plus an Excel template for your product data.
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