Is a QR code mandatory on wine? What has actually been required since December 2023
Since the end of 2023, QR codes have appeared on more and more wine bottles, and many winemakers are asking themselves: Do I need one now? The short answer is no. The long answer is still important for the design of the label.
The information is mandatory, not the QR code
EU Regulation 2021/2117 requires a list of ingredients and a nutritional declaration for wines produced from 8 December 2023 onwards. How this information reaches the customer is left open by the regulation: it may be printed fully on the label. Or part of it is available electronically — in which case a QR code is needed, leading to the so-called e-label.
The two approaches compared
| All on the label | E-label via QR code | |
|---|---|---|
| Space on the label | plenty: ingredients list and full nutritional table | little: calorific value, allergens, the QR code |
| Multiple languages | every language on the label | language versions on the page |
| Changing values | new label | change values on the page |
| What must remain on the label | everything | Calorific value ("E"), allergens with "Contains", standard information |
If a QR code, then according to these rules
- Next to the QR code, it must be clear what it stands for — according to the interpretation of the EU Commission, a mere "i" is not sufficient; "Ingredients" or "Ingredients & Nutritional Values" is common.
- The e-label must not show sales or advertising content.
- It must not collect or evaluate user data.
- The information must be visible without detours: no registration, no general homepage where you have to search.
- The language is determined by the country in which the wine is sold.
What must never be in the QR code
Allergens must be on the physical label, with the word "Contains" — for wine, usually sulphites. The calorific value also belongs on the bottle; it may be abbreviated with "E". And the standard information such as alcohol content, net volume, origin and bottler remain where they always have been.
Who the e-label is worth it for
Especially for wineries with small labels, multiple export languages or many wines. If you sell three wines only domestically and have space on the back label, you can simply print the information. If you decide on the e-label, you need a provider that adheres to the rules on its own — turning off advertising and tracking should not be the task of the winery.
At Same-QR, the template "Wine e-label" is designed this way: no buttons, no shop, no reference to Same-QR, no cookies, and only an anonymous sum is counted without IP address.
Frequently asked questions
Not because of the missing QR code. What matters is whether ingredients and nutritional values are present — on the label or electronically.
No. Wines produced before 8 December 2023 may be sold without this information.
The wine control or food safety authority of the respective country. For questions regarding design, the winegrowers' association is the first point of contact.
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