QR Codes on Wine Labels: What the EU E-Label Actually Requires

Wine got an ingredients list. For products made from 8 December 2023, the EU requires the ingredients and a nutrition declaration to reach the buyer — and because a back label is small and a bottle is not, most producers deliver them electronically, through a QR code on the label. That electronic page is what everyone now calls the e-label.

Making the code is the trivial part. What decides whether it is compliant is what sits behind it.

The two rules that change everything

Almost every QR guide written for wineries treats the code as a marketing channel: point it at your shop, your story, your newsletter. For this particular code, that is exactly what you cannot do.

• The e-label may not carry marketing. The page the code opens is a legal information page. Sales-oriented content does not belong on it — the buying links, the tasting-club sign-up, the campaign banner.
• The e-label may not track the person scanning. Collecting or profiling user data through the mandatory label is not permitted.

Which produces a design most vendors will not tell you about: the mandatory code and your marketing code are two different codes. One goes on the label and opens a clean information page. The other can live on the neck tag, the case, the shelf talker, the tasting-room card — and there you may sell as hard as you like.

What has to be where

• On the physical label: the energy value. It stays on the bottle and cannot be delegated to a scan.
• Behind the code (or on the label, your choice): the full nutrition declaration and the list of ingredients.
• In the right language. The information has to be understood where the bottle is sold, which for an exporter means several languages, not one.

That last point is the one that quietly decides your setup, and it is where a static code fails.

Why the code has to be dynamic

A wine label is printed in tens of thousands, months before the bottle is sold, and the bottle then sits in a warehouse or on a shelf for years. Between the print run and the last bottle sold:

• The blend changes with the next vintage, and so does the nutrition declaration.
• A new export market appears and needs another language.
• Your website is rebuilt and the old address 404s — with a static code, every bottle in the trade now points at nothing.

A dynamic code decouples the print from the page. Same square on the label, destination edited whenever the facts or the languages change. For a product with a multi-year shelf life, this is not a convenience — it is the difference between a correction and a recall of your own labels.

What we record, and why it matters here

Because tracking is the point of contention, here is our list without ceremony. A scan through this service records the time, which code, the device type, the operating system and browser as the request reports them, the referrer if the browser sends one, and a salted hash of the IP address used to count unique visitors.

It does not record any identity, any name, any account — and no location at all, not even a country. Nothing follows the person to another site, and nothing builds a profile.

So the counter tells you a code was scanned 4,000 times. It cannot tell you who, and it is not built to. Whether that satisfies your obligations for a mandatory label is a question for the authority in your market — we are telling you exactly what exists so you can ask it precisely, not assuring you that it is fine.

Printing it on a bottle

Back labels are the most crowded surface in the drinks trade, so the temptation is to shrink the code until it fits. The limits:

• Size. A label is read at arm's length, so roughly 1.5–2 cm across. Smaller works in a bright shop and fails in a dim restaurant, which is where a wine list is actually read.
• Quiet zone. The clear margin around the code is part of the code. Text or a border crowding it is the most common reason a label scans in the studio and not in the aisle.
• Contrast, not house colours. A pale gold code on cream paper is beautiful and unreadable — a camera judges by luminance, not by hue. Our editor checks this while you design and tells you before the print run, which on a label order of 30,000 is the whole point.
• Foil, embossing and varnish. Metallic stock reflects straight into the camera at exactly the angle a person holds a bottle. If the label is foiled, keep the code on a matte patch.
• Curvature. A code wrapped around a narrow bottle bends away from the lens. Keep it near the centre of the label, not at the edge where the glass turns.
• Say what it is. "Ingredients and nutrition" beside the square. A shopper who knows what a code is for scans it; a bare square reads as an advert and gets ignored.

A setup that survives the vintage

1. One dynamic code per wine — not one for the estate. Each wine has its own declaration, and a shared code forces the drinker to hunt.
2. Print the code and a short readable address beside it, so a phone with no camera access is not a dead end.
3. Point it at a plain page: ingredients, nutrition, allergens, language switch. No shop, no newsletter, no banner.
4. Keep a second, separate code for marketing, and put it somewhere other than the mandatory label.
5. Scan the actual printed label, from an actual bottle, in bad light, before the run is approved.

Quick answers

• Is a QR code mandatory on wine? No — the information is mandatory. A code is the usual way to deliver the part allowed to be off-label.
• What must stay on the bottle? The energy value.
• Can the code open my shop? Not the mandatory one. Use a second code elsewhere for that.
• How many languages? Those of the markets you sell into — a dynamic code lets you add one without reprinting.
• What size on a back label? About 1.5–2 cm, with a clear margin, away from foil.
• Do you track drinkers? No identity and no location are recorded. Confirm your own obligations with your market's authority.