New E.U. wine labeling rules state that wines and aromatized wine produced after December 8, 2023 must disclose ingredients, nutritional information, and several other details in a manner that ensures consumers can conveniently access the required information.

This article provides a blueprint for complying with the law using QR codes and digital labels (e-labels), and is based on our work with wine brands both large and small, including Remy Cointreau, Schlumberger, Delicato, Continuum, and others.

Wine producers are overwhelmingly choosing to use QR codes and digital labels for compliance due to two key benefits:

• Costly changes associated with physical label design updates can be avoided by using dynamic QR codes
• QR codes can be printed on labels now, while landing pages (digital labels or e-labels) can be updated and changed over time as needed, even if there are adjustments in the regulations and requirements.

For the rest of this article, we’ll use the term “e-label solution” to refer to any software solution which creates QR codes and the associated, compliant web pages or “digital labels”.

Brands choosing QR codes to become compliant follow these steps to become compliant with the new regulation.

1. Organize wine information in a spreadsheet or database.
2. Input wine information into the e-label software solution.
3. Generate and download the QR codes for use on your printed label design.
4. Design and print the labels with QR codes for placement on wine products.

The above process must be repeated every year for new wines made in that year and destined for sale in the E.U.

What if I’m in a rush to print wine labels with QR codes?

If your winery is in a rush to print labels, it’s possible to start the compliance process by generating the QR codes, downloading them, and printing them on the wine. Updates can be performed later by revisiting steps 1 and 2 above. Check that regardless of which solution you choose you are sure that the e-label solution supports the ability to first print the QR codes and then create or update the digital labels later.

All of these four steps are necessary for compliance, regardless of what order they are performed in. We’ll now go into more detail for each step.

New amendments have been made over time and before the key compliance date of December 8, 2023, so it’s good to keep in mind that guidance and the exact path toward compliance may change over time.

The goal of this step is to have all the wine product information you’ll need to input into your software labeling solution (e-label solution) organized. This can be done in a spreadsheet or a database. The following information includes both recommended (optional) and compulsory information for digital wine labels:

Product information

• Wine variety
• Nutritional information
• Allergen declaration
• Origin country
• Importer, bottler and producer
• Geographical Indications
• Vintage year
• Alcohol by Volume percentage (ABV)
• Net quantity in milliliters
• Sugar content
• Vine variety specific to the vintage
• Product description
• Date of expiration

Serving sizes

The law requires nutritional and energy information based on a 100ml serving. You can optionally also provide information based on another serving size. Typically the more popular wines, red, white, and rosé are served in 125ml, 175ml, and 250ml amounts. The standard serving across bars in Europe is 125ml, but you may also want country-specific ones. Besides the required 100ml serving size declarations, we recommend also displaying them for a standard serving size as this information can be more useful for customers.

Date of expiration

For wines that have been (partially) de-alcoholized with an ABV less than 10%, you’ll need to provide a date of minimum durability, or an expiration date. This is referred to in regulation (EU) 2021/2117.

Ingredients

Ingredients must be listed in descending order of weight on the e-label, so you should organize your information this way and as indicated in Article 18 of regulation (EU) 1169/2011. Additives should be organized by category.

Nutritional facts

You’ll need to prepare the following nutritional facts for each wine product:

• Energy (may or may not be auto-calculated by your e-label solution)

• Saturates

• Sugars

• Fat
• Carbohydrates
• Protein
• Salt

Your e-label solution should provide a calculator for energy, though you can specify energy directly yourself. More on those methods will be explained in the next section.

Allergens and intolerances
Any allergens or intolerances must be printed on the physical label and, if you are using and e-label or digital label solution, those must be displayed there as well. See (Article 21(1)(b) of regulation (EU) 1169/2011).

Common questions about energy, ingredients, and additives

How do you calculate energy?

According to the regulation there are two acceptable methods of calculating energy:

• Method 1:  Formula calculator with conversion factors based on sugar, alcohol, and a few other parameters.
• Method 2: Using a general average value per wine type, such as red-dry, sparkling-brute etc. The table is provided in this self regulatory document 

What is defined as an ingredient? Ingredient means “any substance or product, including flavorings, food additives and food enzymes, and any constituent of a compound ingredient, used in the manufacture or preparation of a food and still present in the finished product, even if in an altered form; residues shall not be considered as ‘ingredients’” (Article 2 of (EU) 1169/2011)

What if one of your suppliers provides you with base wines or pre-mixed ingredients which your brand incorporates into your wines? The current trend is for winemakers to contractually obligate their upstream wine and/or ingredient providers to provide ingredient and additive information for such inputs to their wines. They then merge this with their own ingredient and additive information to create a final ingredient and additive list for each SKU.

What if you are mixing older wine or vintages with unknown ingredients, i.e., champagne houses with non-vintage products which are a mix of older and newer vintages? The law is still being finalized but a draft regulation that is expected to pass soon has addressed this. Based on the draft regulation, it is likely that the final law will be written in such a way as to allow wines that mix different vintages to simply have one exhaustive list of additives and ingredients.

Additives and processing aids

As from 8th December 2023, it will be authorized to indicate, in the list of ingredients of wine products, the ‘acidity regulators’ and ‘stabilizing agents’ by means of no more than three alternative ingredients, where they are similar or mutually substitutable in their function, provided that at least one of those additives be present in the final product. The expression to be used in the list of ingredients is “contains… and/ or” followed by no more than three additives.”

What if additives vary from batch to batch? This will be authorized only for additives falling under the categories ‘acidity regulators’ and ‘stabilising agents’ and up to no more than three alternative ingredients. The expression to be used in the list of ingredients is “contains… and/ or” followed by no more than three additives.

What about translations? Do you need to translate the e-label to all E.U. languages?

The law requires making e-labels available in the language(s) used in the markets the products are sold. It further states that E.U. member countries can specify the languages which e-labels must be displayed in.

Given this, most global brands are creating translated versions of their e-labels in all 24 E.U. languages, with the language displayed depending on either the country where the e-label QR code is scanned or the language of the user’s system.

Depending on your solution, you may need to organize translations of your product information and ingredients in this step. More advanced solutions with auto-translation and translation management mean you don’t have to worry about preparing this information now, and can simply review/ polish translations later.

Once you have gathered the above information for each of your wine products, you can proceed to Step 2.

There are three options for this:

1. Manual entry: Copy and paste from your spreadsheet or database created in Step 1 into the software solution. This is only practical if you have a few or, for example, a few dozen SKUs.
2. Bulk upload: This refers to uploading a document such as a CSV, etc. to your e-label solution. This is advisable if you have a few dozen to hundreds of SKUs, and would save significant time in your process. It would also help prevent data input errors which could impact your compliance. This feature must be supported by your software solution.
3. Integrations via APIs: This is advisable if you have a few dozen to hundreds of SKUs and if your solution supports it. This approach has similar benefits to bulk upload. This feature must be supported by your software solution.

Depending on your solution, you might be inputting translated versions of ingredients and product information in this step. Established solutions provide vetted translations for common terms, auto-translation, and translation management, which would only require polishing and reviewing translations at this stage.

Each wine product (SKU) will have it’s own e-label and it’s own QR code. So if your brand has ten different wines, with ten different e-labels, you will have ten different QR codes. This is unless you are using serialized, unique QR codes for advanced functionality like supply chain traceability, which is beyond the scope of this article and not common yet in the wine industry.

Once you’ve designed your e-labels, you should be able to generate and download the QR codes that point to them.

Your QR codes should be downloaded in a format that is usable by your printer or easily integrated into your printing process.

You’re now ready to design your QR codes on your labels. Keep in mind the following best-practices and recommendations.

Please keep in mind that if your winery is in a rush to print labels, it’s possible to start by generating the QR codes, downloading, and including them in your label designs first. So long as you have control of those QR codes via your software or other system, and return to the above steps later, this is perfectly fine.

Where should the QR code be placed on the label?

Most wineries are choosing to put the QR code on the back label to minimize impact to branding.

What should be written on or in the QR code?

Several companies prepared to print, or have chosen to print, QR codes with an “i” symbol in the center of the QR code to represent “get more info”. Others have included “Scan for info” or “Scan for more info” and placed this adjacent to the QR code. This latter “call-to-action” with clear explanation as to the contents of the site accessed by the QR code satisfies the latest regulatory requirements. Unfortunately, the “i” symbol is explicitly not sufficient and has been deemed too ambiguous.

It’s important to consider that the QR codes may be scanned in other markets outside of the E.U. Prioritizing different information for those consumers in other regions, for example branding for the product or winery, authenticity check features, etc. can all be accounted for and redirected based on geo-location parameters and triggers.

If you decide to use a “call-to-action” near the QR code, be sure that it will be suitable for all regions and relevant to the content that may be served to the consumer.

How big should the QR code be printed on the label?

We recommend a minimum size of 13mm x 13mm and a maximum size of 16mm x 16mm for the QR code, not including the quiet zone (see below). On the lower end of this spectrum (6mm x 6mm), a consumer will have to position their camera a few inches from the QR code to be able to scan it. At the larger end, they will have to be farther away. Anywhere in the range is acceptable, but we recommend something in the middle so that consumers have no issues scanning.

All QR codes must have a “quiet” zone – a white area around the QR code. We recommend four times the size of individual cells in the QR code – for reference, this would be 1.5 mm for a 10 mm QR code.

You should confirm with your label designer and/ or printing provider that the QR code image you download from your e-label solution can be printed at 300 dpi or higher at your desired size on the label.

What color should the QR code be?

We recommend a black QR code on a white background. Other dark colors on white or light background may be possible, but should be tested by scanning a print test with a standard QR code reader app. White on black background (inverted) can also work, but should be tested as it requires sufficient contrast.

Can the QR code be a different shape?

QR codes can only be square shaped. Creative effects can still be achieved despite this by embedding square QR codes in shapes that are not square e.g. a rotated square, a parallelogram diamond, etc. In these cases, keep an eye to maintaining the requisite quiet zone.

What resolution should the QR code be printed at?

We recommend 300 dpi or higher to prevent issues with scanning by consumers.

That’s it! If you’ve finished Steps 1 through 4 as described above, you can apply your wine labels – with QR codes – onto the wines you wish to make compliant with the E.U. law.

Can you switch to a different e-label vendor after QR codes from that vendor have already been printed on labels applied to wines? How does vendor lock-in work with digital wine labels and QR codes?

Your options depend on your implementation.

There are three approaches:

1. Using a static QR code which cannot easily be changed (NB: don’t do this!)
2. Use a dynamic QR code with a future redirect option
3. Use your domain for the QR codes, including the function for dynamic redirect

Let’s use an example involving two electronic label solution providers, Provider A and Provider B. You start your implementation with Provider A, generate QR codes using their solution, and print those codes on your wine labels. After a year you aren’t satisfied with their service or have encountered some other difficulty and want to move to Provider B.

For new wines, you can simply use Provider B to generate the new e-labels and QR codes.

However, for the wines which already have printed labels with Provider A’s QR codes, the QR codes you printed on wine labels have Provider A’s website domain name in them, and customers who scan those QR codes would still go to a website that they control. This is far from ideal.

Option 1 – Static QR code

This means you are using a URL in the QR code that was not meant to be redirected to a new URL. Depending on who controls the domain and server related to the URL in the QR code, it may be impossible to change the URL. That leaves you completely locked-in. This is a major reason why static QR codes are not recommended.

Option 2 – URL redirection

If Provider A offers URL redirection even after you terminate use of their e-label service, then anytime a customer scans a QR code on a wine with QR codes from Provider A, that customer would first open a webpage hosted by Provider A, then their browser would redirect them to the e-label on Provider B’s platform.

Some solutions, including association-backed ones, claim they will provide URL forwarding if you terminate with them. But even in this case, you are taking them at their word that they will provide that technical service, even at a fee, reliably, for as long as your wines are on the market.

This is why it’s essential to choose a solution provider who is an established company, with established customers, who you know will be around while your wines are on the market.

Option 3 – Use your own domain in the QR codes

This requires a bit of preparation and is a more advanced approach. In this scenario, the e-label solution uses your own domain name. That way, if you ever decide to leave the service and host e-label pages elsewhere, you won’t be locked in at all – you control the website address inside the QR code.

We recommend using your own domain name in the QR code if you’re worried about vendor lock-in or are a large global brand with specific requirements for this level of control. You should consider asking your e-label solution provider early on in the project what is required to use your own domain name for the URLs in the QR codes.

Can you have one QR code serve multiple purposes, including e-label?

Your e-label can have a direct link to your website, but you cannot link to pages with marketing information, such as, but not limited to:

• Webshops
• Product sales
• Event invites
• Newsletter
• Loyalty programs etc.

Until now, there has been no further definition of what does and does not constitute “marketing information” provided by the regulator.

What capabilities in an e-label solution are usually required by a global wine brand seeking compliance?

The following technical capabilities (features) are usually required by larger wine brands:

• Bulk upload of SKU information and/or APIs – This can save significant time doing manual entry for many SKUs and prevent typos which could impact compliance.
• Auto-translation and translation management – Similar to the above, saves time and ensures compliance.
• Solutions for expected future compliance requirements – It’s expected that many country-specific recycling and anti-waste labeling laws similar to those recently released in France and Italy will emerge, not to mention pending wine and spirits labeling rules being evaluated in the U.S. by the TTB. Having a global solution prevents need to integrate new QR code solutions each time a new law emerges.
• Intelligent URL scan destination for non-E.U. markets – Provides a useful scan experience for non-E.U. consumers who do not require the E.U. e-label.
• GS1 compatibility – Ensures your QR codes are compatible with this important emerging standard, where QR codes will replace the existing 2D barcodes on products.
• Security and availability uptime guarantees/ SLA
• Global and multilingual support team and onboarding, support materials

Scantrust is excited to offer our technology and expertise to remove the headaches involved in complying with the E.U. wine labeling rules. Learn more about our solution, sign up for our free tool, or contact us today to learn about our enterprise options. We also provide information sessions about the EU wine label regulations and our own solution. You can view a recording of one that took place on May 4, 2023 right here: