Compliance guide
EU wine labelling and the QR code: your guide to Regulation 2021/2117
Since 8 December 2023, every bottle of wine and aromatised wine product placed on the EU market must declare a full ingredient list, a nutrition declaration, allergens and an energy value. Here's what has to stay on the glass, what can move behind a QR e-label, and how to comply.
Guidance only, not legal advice · Reviewed 2026 against EUR-Lex 2021/2117 & Commission guidance C/2023/1190.
What the law requires
EU Regulation 2021/2117 amended the Common Market Organisation Regulation (1308/2013) for wine and Regulation 251/2014 for aromatised wine products, removing their long-standing exemption from mandatory ingredient and nutrition labelling. Wine now carries the same core consumer information as other foods. You must declare:
- A full list of ingredients — everything used in production that remains in the finished product, including additives such as added sulphites, acidity regulators and stabilisers.
- A nutrition declaration — energy plus fat, saturates, carbohydrate, sugars, protein and salt, per 100 ml.
- The energy value in kJ and kcal per 100 ml. Where the full nutrition declaration is provided electronically, the on-pack energy value may use the symbol "E" followed by the value.
- Allergens (for wine, most commonly sulphites; sometimes milk- or egg-derived fining agents).
Who and when
The rules apply to wine and aromatised wine products marketed in the EU, of all sizes — there is no general small-producer exemption, and imports must comply. The new particulars apply to products placed on the EU market from 8 December 2023. Wine produced or imported before that date may be sold under the old rules until stocks are exhausted, so older vintages don't need relabelling.
What can go behind the QR (and what can't)
This is what saves your label design. You may limit the on-pack nutrition information to the energy value alone, and provide the full nutrition declaration and full ingredient list electronically via a QR code.
Must stay on the physical label:
- The energy value — in the same field of vision as the other compulsory particulars.
- Allergens (e.g. "contains sulphites") — never allowed behind the QR.
- The other mandatory wine particulars (category, alcoholic strength, provenance, bottler, net quantity, lot number, PDO/PGI).
- The QR code / link itself, in the same field of vision as the other compulsory particulars.
May be provided electronically (behind the QR): the full ingredient list and the full nutrition declaration.
Three hard rules govern the e-label: no user-data collection or tracking (no analytics cookies, no logins), no marketing content, and direct, universal access to the information (no paywalls or app installs).
The language trap
The ingredient list and nutrition declaration behind the QR must be available in the official language(s) of every EU country where you sell. The EU has 24 official languages, so selling across the single market can mean supporting up to 24. A single English-only e-label page is not compliant for a wine sold in, say, France, Germany and Italy — which is why static PDFs or hand-built pages become unmanageable fast.
How to comply, step by step
- Build an accurate ingredient list per product from real production records.
- Calculate the nutrition declaration (energy + fat, saturates, carbohydrate, sugars, protein, salt per 100 ml).
- Put the mandatory items on the glass — energy value + allergens — with the energy value and QR link in the same field of vision.
- Create a compliant e-label for the full ingredient list and nutrition declaration: neutral, no tracking, no cookies, no marketing.
- Translate into every selling market's official language(s).
- Generate a QR code (ideally dynamic, so you can update content without reprinting) at a scannable size.
- Keep it current and tie each label to its batch for traceability.
How fermt's digital label handles this
Because your recipes, batches and ingredients already live in fermt, your label doesn't start from a blank page. fermt publishes multilingual QR product labels that carry ingredients, provenance and cask/vintage history straight from your production data — and for wine specifically it tracks vintages, ageing and provenance.
- Ingredients & nutrition behind the QR, generated from your real batch data.
- Multilingual labels (English, Danish, German, Spanish, French, Italian today) — addressing the cross-border language obligation.
- EU-hosted, GDPR-by-design, and the public label page runs no analytics or tracking — aligned with the e-label's no-user-data rule.
- Live updates, so a recipe or vintage change updates the label without reprinting the code.
Frequently asked questions
Does every wine sold in the EU now need a QR code?
No. A QR code / e-label is optional. You may print the full ingredient list and full nutrition declaration on the physical label instead. The QR route simply lets you move those two items off the glass — but the energy value and allergens must stay on the physical label either way.
What information must stay on the physical bottle label?
At minimum the energy value (kJ/kcal per 100 ml, or the "E" symbol when the full declaration is electronic) and all allergens/intolerance substances (e.g. "contains sulphites"), plus the existing mandatory wine particulars. The QR link and the energy value must sit in the same field of vision as the other compulsory particulars. Only the full ingredient list and full nutrition table may move behind the QR.
Can I use my wine’s QR code for marketing or to collect visitor data?
No. The e-label must be a neutral page with the mandatory information only. It must not collect or track user data and must not carry marketing or commercial content. Use a separate marketing URL for promotion.
When did the rules start, and do old vintages need relabelling?
The requirements apply to products placed on the EU market from 8 December 2023. Wine produced (or imported) before that date can be sold under the old rules until stocks run out, so older vintages generally don’t need relabelling.
How many languages does my e-label need?
The mandatory information must be in a language easily understood in each Member State where you sell, and Member States may require their official language(s). Selling across the whole EU can mean supporting up to 24 official languages — an English-only page is not enough for most export markets.
Does this apply to aromatised wine products too?
Yes. Regulation 2021/2117 removed the exemption for both wine (Regulation 1308/2013) and aromatised wine products (Regulation 251/2014), so both now require the ingredient list and nutrition declaration.