E-label without tracking: Why we only count anonymously for wine QR codes
Most QR code services advertise statistics: how often scanned, when, where, with which device. This is useful for a poster or a flyer. For a wine e-label, this can become a problem.
What the EU Commission requires
In its notice on the electronic labelling of wine in November 2023, the Commission drew two boundaries. First: The e-label must not appear together with information for sales or marketing purposes. Second: It should not collect or track user data. The idea behind this is simple: Mandatory information is a consumer right. Anyone who wants to know what is in their wine should not become a data provider for that purpose.
What falls under this
- Analysis tools such as Google Analytics or advertising pixels on the e-label page
- Cookies and browser storage that recognise a visitor
- Evaluating the location, device or origin of scans
- A cookie banner that asks for consent before the information
- Newsletter fields, competitions and shop links
And a simple scan count?
There is no explicit ban on counting. What is prohibited is collecting data about users. However, many scan counters do exactly that: To ensure a phone is not counted twice, they remember the IP address or a value derived from it — this is already processing user data. With e-labels, Same-QR therefore counts purely anonymously: Each scan and each view only increases a total. No IP address, no derived value, no memory aid, no cookie. The price for this is small — if someone scans twice, it counts twice. Detailed statistics are available on the winery page, where marketing is permitted.
How the e-label is built at Same-QR
| Requirement | Implementation at Same-QR |
|---|---|
| No advertising, no sales | Template without buttons, offers, or shop links |
| No third-party names | No "Created with Same-QR" notice, even in the free tier |
| No user data | Only an anonymous sum of scans and views — no IP address, no cookies, no browser storage |
| No third-party providers | No scripts, fonts or images from third-party servers |
| No barrier before the information | No cookie banner, no login, no intermediate page |
What you should watch out for yourself
One field remains in your hands: "Further information" is intended for bottlers, batch numbers or disposal instructions. Advertising text, discount codes or shop addresses do not belong there — otherwise the e-label becomes a marketing channel again. For everything that aims to sell, there is the winery page with its own code.
Frequently asked questions
Yes, as an anonymous total. You can see how often it was scanned and viewed, but nothing about the visitors — no location, no device, no return visits. Double scans of the same phone are counted twice.
Not with Same-QR: The page does not set cookies and does not load anything from third-party servers, so there is nothing for which consent would be required.
We voluntarily comply with the Commission's requirements. For the content — ingredients, values, labelling next to the code — the winery remains responsible; in doubt, the winegrowers' association can help.
Reserve your spot before we go live.
One email as soon as the tool goes live — including pricing and the free plan. No spam, unsubscribe any time.
- Your free account is reserved — there is nothing to pay yet anyway
- 90 days of unlimited destination changes instead of 30, only for early sign-ups
- Launch price locked in, even if we raise prices later
By subscribing you consent to receiving the newsletter. You can withdraw consent at any time via the unsubscribe link in every email.