The new EU wine labelling rules stipulate that wines and aromatized wines produced after 8 December 2023 must provide the consumer with nutritional information and other details in a way that ensures easy access to the required information. One feasible solution is the electronic wine label via QRCODE.
This article provides information on regulatory compliance using QR codes and digital labels (e-labels).
- The advantages of implementing a QR-code solution for EU wines
- What is the process for creating a digital/electronic wine label through the automated wine e-label platform?
- What if I'm in a hurry to print wine labels with QR codes?
- Four essential steps to comply with the regulation
- Can you have a QR code for multiple purposes, including electronic labeling?
- What happens if I choose to change my e-label provider?
The advantages of implementing a QR-code solution for EU wines
Wine producers are expected to overwhelmingly choose to use QR codes and digital labels to comply with the new regulation due to three key advantages:
- Firstly, the QR code offers a space-saving solution without compromising the label design as well as savings on the costly changes associated with changes to the physical label design.
- Secondly, QR codes are dynamic, which means that the information behind the QR code can be updated at any time. This is particularly important, as it is common for the final data of the bottled wine to often not be available when the labels are printed. Thanks to dynamic QR codes, however, this data can be added at the time the product is released to the market. Thus, QR codes can be printed on the labels immediately, while the landing pages (digital labels or e-labels) can be updated and changed over time as needed, even if there are adjustments to the regulations.
- Thirdly, QR codes also allow for easy integration in online stores in price lists or brochures as legislation requires that the consumer must have access to nutritional information even when ordering the wine (e.g. online via an e-shop, in a restaurant menu, etc.)
What is the process for creating a digital/electronic wine label through the automated platform wine e-label
Step 1
The wine producer fills in the necessary information through an easy-to-use questionnaire form on the Wine – E labels.eu platform.
Step 2
The platform automatically creates the digital label and its QR-CODE.
Step 3
The producer prints the QR-CODE on the physical wine label
Step 4
After scanning the QR-CODE, the consumer gains access to the electronic label.
The above process must be repeated each year for new wines produced that year and intended for sale in the EU.
What if I'm in a hurry to print wine labels with QR codes?
If your winery is in a hurry to print labels, it is possible to start the compliance process by generating QR codes, downloading them, and printing them on the physical wine label. Updates to the electronic label can be made later, when the wine is on the market for sale. Therefore, it is important to choose an e-label platform that supports the ability to print QR codes first and create or update digital labels later. The platform wine-elabels.eu has you fully covered on this.
Four essential steps to comply with the regulation
Note: It is good to keep in mind that compliance guidelines may change over time.
Step 1: Organize your product information
The goal of this step is to organize all the information about your wine products that you will need to enter into the digital label platform. This can be done, for example, in a spreadsheet. The following information includes optional (recommended) and mandatory information for digital wine labels:
Product (wine) Information
- Trade name (Trademark)
- Country of origin
- Importer, bottler and producer
- Geographical Indications
- Vintage
- Net product quantity – volume in milliliters
- Nutritional information
- Allergen declaration
- Alcohol by volume (ABV)
- Sugar content
- Grape variety/varieties and their percentages
- Product description
- Expiration date
Serving sizes
The law requires nutrition and energy information based on a 100 ml serving. You can also optionally provide information based on another serving size as well as a standard serving size (e.g. 125 mL, as this information may be more useful to customers)
Expiration date
For wines that have been (partially) de-alcoholized with an ABV of less than 10%, you must provide a minimum strength date or an expiration date. This is stated in the Regulation (EU) 2021/2117.
Components
Ingredients must be listed in descending order of weight on the electronic label, so you should organize your information in this manner and as stated in Article 18 of Regulation (EU) 1169/2011 Also, plugins should be classified based on their functional category. The platform wine-elabels.eu gives you this option automatically.
Nutritional elements
You will need to prepare the following nutritional information for each wine product:
- Energy (The platform wine-elabels.eu can calculate it automatically by simply entering the chemical analysis data)
- Total fat
- Saturated fat
- Total carbohydrates
- Sugars
- Proteins
- Salt
The e-label solution you choose should provide an automatic solution for calculating energy, although you can calculate the energy directly yourself. The platform wine-elabels.eu has you covered on this.
Allergens and intolerances
Any allergens must be printed on the physical label and, if you use an electronic or digital label solution, they must also appear there. See (Article 21(1)(b) of Regulation (EU) 1169/2011) .
Frequently asked questions about energy, ingredients and additives
How is the energy of wine calculated?
According to the regulation, there are two acceptable methods for calculating energy:
- Method 1: Formula calculator with conversion factors based on sugars, alcohol and some other parameters (acidity, polyols).
- Method 2: Using a general average price per type of wine. The table is provided in this self-regulatory document
What is defined as an ingredient?
Ingredient means “any substance or product, including flavourings, food additives and food enzymes and any component of a compound ingredient, used in the manufacture of a food and still exists in the final product even if in modified form (residues are not considered to be “ingredients” (Article 2 (EU) 1169/2011))
Food additives are considered an ingredient according to the general definition of "ingredient" as provided for in FIC regulation [Article 2(2)(f)] and, therefore, all additives used in the production of wine form an integral part of the list of ingredients.
According to Article 20(b) of the FIC regulation, food additives and enzymes used as technological aids [processing aids] are not required to be included in the list of ingredients.
However, Article 9(1)(c) of the same Regulation provides for the mandatory indication of any ingredient or processing aid causing allergies or intolerances used in the production of the product and still present in the finished product, even in a modified form.
All additives and processing aids permitted in wine production in the EU are set out in Annex I, Part A, Table 2 of the delegated act Regulation (EU) 2019/934.
What about translations? Do you need to translate the electronic label into all EU languages?
The law requires electronic labels to be available in the language or languages used in the markets where the products are sold. It also states that EU member states can determine the languages in which electronic labels must appear.
Based on this data, it is preferable to have the ability to automatically translate electronic labels into all 24 EU languages, with the language displayed depending on either the country where the QR code of the electronic label is scanned or the language of the user's system.
The platform wine-elabels.eu provides the ability to automatically translate ingredients into the 24 official languages of the EU. There is also support for correcting translations that may not appear correctly.
Step 2: Enter wine product data (SKU) into the digital label platform.
The producer enters the product data into the platform. The platform will then automatically create the electronic label and the QRCODE that corresponds to it.
Step 3 – Download QR codes
Each wine product (SKU) will have its own electronic label and its own QR code. So for example, if the producer has five different wines, with five different electronic labels, you will have five different QR codes.
After you have created your electronic labels, you will then be able to download the QR codes that refer to them.
QR codes should be obtained in a format that can be used by your graphic designer or easily integrated into the printing process.
Step 4 – Print the code QR on the natural wine label
Now you are ready to print QR codes on your labels. Keep in mind the following best practices and recommendations.
Download the QR codes of the e-labels you created and send them to your graphic designer to integrate them into the bottle label. With the green button [Print QR Code (PDF)] You can download the QR CODE in PDF (vector) format. It is the file format that graphic designers usually prefer for better resolution. You can also download it as a PNG (raster) image with the blue button [Download (PNG)].
Please note that if your winery is in a hurry to print labels, you can start by creating the QR codes first and embed them in your labels. Later, before releasing the product to the market, you can fill in the details of the electronic wine label corresponding to the QRCODE you have already printed.
Where should the QR code be placed on the label?
Most wineries choose to place the QR code on the back label to avoid having to change the layout of the main (front) label. Where the nutrition declaration and/or the list of ingredients is provided electronically, the link (QR code or similar code) to the nutrition declaration and/or the list of ingredients must be presented on the label in the same field of vision as the other mandatory information.
What should be written on or inside the QR code?
The presentation of a QR code should be clear to consumers as to its content, i.e. the mandatory information presented by electronic means. General indications or symbols (such as the ‘i’) are not sufficient to fulfil the requirements of this provision. As stated in Article 18(1) of the FIC Regulation, a heading (text) should be used next to the QR code that clearly indicates the purpose of the QR code. This text should contain the word ‘Ingredients’. The suggestions are to use the expressions: "ingredients" ή "ingredients and nutritional values" ή "ingredients/nutritional values"The expression "ingredients» It can be written in any EU language, however if the label is in English, it would be better to write it in English as “ingredients”.
What size should the QR code be printed on the label?
Size: According to international standards (ISO/IEC 15415) the QR code must be at least 11,49 mm x 11,49 mm. Then, there should be a blank margin to bring the total size to 14,66 x 14,66 mm.
It should have high contrast, ideally black on white.
What color should the QR code be?
We recommend a black QR code on a white background. Other dark colors on a white or light background may be possible, but should be tested by scanning a test print with a standard QR code reader application. White on a black background (inverted) may also work, but should be tested as it requires sufficient contrast.
What else should be listed on the physical label?
It is mandatory to include in the same field of view as the QR CODE the energy in kj and kcal in the format: 100 mL: E= XXX kJ/ XXX kcal. It is important not to use capital letters when writing kJ and kcal.
Also, where the full list of ingredients is provided by electronic means, substances causing allergies or intolerances must be presented on the packaging or on the attached label, but not necessarily in the same field of vision as other mandatory information (the derogation in Article 40(2) of Delegated Regulation (EU) 2019/33 applies).
Can you have a QR code for multiple purposes, including electronic labeling?
Your e-label can link directly to your website, but you cannot link to pages with marketing information, such as, but not limited to:
- Online stores
- Product sales
- Event invitations
- Newsletter
- Loyalty programs, etc.
What happens if I choose to change my e-label provider?
Can you switch to a different e-label supplier since the QR codes from that supplier are already printed on labels that are affixed to the wine bottles? How does supplier lockout work with digital wine labels and QR codes?
You can opt out at any time. If you choose to terminate your use of the service, the platform wine-elabels.eu provides a QRCODE redirection function for a small fee per label. This will allow the already created QRCODES that have been printed to continue to work under the new URL that you will define from your new provider. This is very important as the platform does not "lock you in".
This is why it is essential to choose a provider like wine-elabels.eu which is an established business, with a long-standing presence in the market.