The European wine industry has entered a new era of transparency with a landmark update to wine labelling legislation. From 8 December 2023, all wines marketed in the European Union (EU) must comply with updated requirements that include ingredient lists, nutritional information, allergens and energy values — and offer key data through QR code e-labels.
This article provides a clear overview of the QR code compliance requirements under Regulation (EU) 2021/2117, what winemakers must do to comply, and best practices for implementation.
🧾 1. What Regulation EU 2021/2117 Introduces
Regulation (EU) 2021/2117 amends the EU Common Market Organisation (CMO) rules for wine labelling, aligning wine with the EU’s food information rules and requiring:
- Mandatory display of nutritional values and ingredients for wine products;
- Consumers must be able to access this information either on the label or via an electronic label (e-label) accessed through a QR code on the bottle;
- Producers must ensure the information is clear, accurate, and easily accessible.
While the regulation itself is the legal foundation, the detailed rules about how to implement QR codes and e-labels have been clarified through EU guidance and delegated acts.
📱 2. What QR Codes Mean in Practice
Rather than printing extensive nutritional and ingredient information directly on crowded physical labels, producers can use QR codes linked to e-labels, providing:
✅ A full list of ingredients;
✅ Nutrition declaration (including energy, calories, and nutrient breakdown);
✅ All required data in the language(s) of the destination market.
Key points regarding QR code usage:
- A unique QR code per wine SKU must be present, though solutions like collective QR codes for wine lists are permitted in specific contexts (e.g., restaurant menus).
- The e-label page accessed by the QR code must be neutral, i.e., it cannot include marketing content or tracking technologies (no analytics cookies).
- Dynamic QR codes are allowed — meaning the printed code remains the same even if the linked e-label contents are updated.
In essence, QR codes become an efficient, modern alternative to space-intensive print labels while fully satisfying EU legal requirements.
📅 3. When These Rules Apply
The key date for enforcement is 8 December 2023:
- Wines produced before this date may continue to be sold under previous requirements until existing stocks are depleted;
- Wines produced after this date must comply with the updated regulations, including QR code e-labels.
Failure to comply can result in sanctions, product removal from the EU market, or administrative penalties under EU law.
🧠 4. What Must Appear Physically vs Electronically
EU guidance distinguishes between information that must be printed directly on the label versus what can be provided electronically:
Must be physically displayed on the bottle:
- Allergenic substances and intolerances;
- Energy value (e.g., calories per 100 ml);
- Other standard label elements such as alcohol content, category, origin, bottler, lot number, etc.
Can be provided via QR codes / e-labels:
- Full nutrition table;
- Ingredient list;
- Extended product details in relevant EU languages.
This hybrid approach reduces label clutter while ensuring consumers still have full access to required data.
🌍 5. Why QR Code Compliance Matters
The updated EU wine labelling rules increase transparency and align wine labelling with general food labelling standards. This creates:
✔ Better consumer information and trust;
✔ Flexibility for producers reducing print complexity;
✔ Opportunities to localize information automatically depending on where the bottle is scanned.
With the rise of QR technology and smartphones, this model delivers compliance in a consumer-friendly way.
🧩 6. Best Practices for Implementation
To comply effectively, wine producers should:
📌 Use professional e-label platforms designed for EU compliance;
📌 Generate unique QR codes for each wine SKU;
📌 Ensure e-labels contain ONLY legally required info (no marketing content);
📌 Support e-labels in the official languages of the EU markets where the wine is sold;
📌 Regularly review and update nutritional data after lab tests or new vintages.
Using dynamic QR code services and e-label management tools increases accuracy and reduces costly misprints.