TL;DR
- Since 8 December 2023, wine and aromatized wine products sold in the EU must declare their ingredients and nutrition, under Regulation (EU) 2021/2117.
- Both may be provided by electronic means, an e-label usually reached through a QR code, except the energy value, shown with the symbol "E", and allergens, which stay printed.
- The e-label page must not collect or track user data, must not carry marketing content, and must be in a language the consumer understands.
EU Regulation 2021/2117 requires wine labels to show a nutrition declaration and a list of ingredients, for wine produced from 8 December 2023. Producers can print both in full, or print only the energy value and the allergens and put the rest on an e-label: a web page reached from the bottle, usually through a QR code. The e-label makes the change workable on a small label, but it comes with conditions on what the page may show and do.
EU Regulation 2021/2117 at a glance
| What it is | Regulation (EU) 2021/2117, part of the 2021 reform of the EU's Common Agricultural Policy |
| Published | 2 December 2021 |
| Wine labeling rules apply from | 8 December 2023 |
| Products | Wine and aromatized wine products, such as vermouth, placed on the EU market |
| New mandatory particulars | Nutrition declaration and list of ingredients |
| Must stay printed | The energy value, with the symbol "E", and allergens |
| Can move to an e-label | The full nutrition declaration and the full ingredient list |
| E-label conditions | No collection or tracking of user data, no marketing content, a language the consumer understands |
| Penalties | Set by each Member State |
What Regulation 2021/2117 changed for wine labels
Regulation (EU) 2021/2117 is an amending regulation. Among other laws, it changed Regulation (EU) No 1308/2013, which holds the labeling rules for wine, and Regulation (EU) No 251/2014 on aromatized wine products. It also touches geographical indications and the EU's outermost regions, but for producers the change that matters is on the label.
Before the reform, wine did not have to list ingredients or nutrition values: Regulation (EU) No 1169/2011, the general EU food information law, exempts drinks above 1.2% alcohol by volume from both. Regulation 2021/2117 added the two particulars to the wine labeling rules, with a transition that ended on 8 December 2023.
Which products the rules cover
| Product | Covered by the ingredient and nutrition rules |
|---|---|
| Wine, including sparkling, liqueur and semi-sparkling wines | Yes |
| Dealcoholized and partially dealcoholized wine | Yes |
| Aromatized wine products, such as vermouth and other aromatized wine-based drinks | Yes |
| Wine produced before 8 December 2023 under the earlier rules | No, it may be sold until stocks run out |
| Spirit drinks, beer and cider | No, they fall outside this Regulation |
The rules apply to all wine placed on the EU market, imports included.
What stays on the label and what can move to the e-label
| Information | On the printed label | On the e-label |
|---|---|---|
| Energy value, in kJ and kcal, with the symbol "E" | Required | Also part of the full nutrition declaration |
| Allergens, such as sulfites, or egg and milk products used in fining | Required | Also part of the full ingredient list |
| Full nutrition declaration: energy, fat, saturates, carbohydrate, sugars, protein and salt | Optional | Allowed instead of the label |
| Full list of ingredients | Optional | Allowed instead of the label |
| Other mandatory particulars, such as alcoholic strength and nominal volume | Required | Not a substitute |
| Marketing content | Allowed on the label | Not allowed |
The e-label replaces only the two new particulars. Everything else still has to be printed.
What the e-label page may and may not do
| Rule | What it means in practice |
|---|---|
| No collection or tracking of user data | No analytics cookies, tracking pixels, sign-ups or location requests on the e-label page |
| No marketing content | No offers, shop links, recipes or newsletter forms; put promotional content on a separate page |
| A language the consumer understands | Under Article 15 of Regulation (EU) No 1169/2011, the information must be in a language easily understood by consumers in the country where the wine is sold |
What goes in the nutrition declaration and the ingredient list
The nutrition declaration covers the energy value, in kJ and kcal, and the amounts of fat, saturates, carbohydrate, sugars, protein and salt, per 100 ml, usually as a table. The values are averages, from the producer's analysis, the known average values of the ingredients, or generally established data.
The ingredient list follows the general EU rules: a heading that includes the word "ingredients", then each ingredient by its specific name, in descending order of weight. For wine that typically means grapes, plus any of the following used:
| Category | Examples |
|---|---|
| Base ingredients | Grapes, grape must, concentrated grape must, sucrose, expedition liqueur |
| Acidity regulators and stabilizers | Tartaric acid, citric acid, gum arabic, yeast mannoproteins; these may be listed with "may contain" |
| Preservatives and antioxidants | Sulfur dioxide, potassium sorbate, lysozyme, ascorbic acid |
| Packaging gases | Argon, nitrogen, carbon dioxide; these can be covered by "bottled in a protective atmosphere" |
The wine label reform article lists more entries.
How to set up a compliant wine e-label: seven steps
- Collect the data for each wine. Get the nutrition values per 100 ml and the ingredient list for each wine and vintage. Treatments change between vintages, so treat each one as its own record.
- Decide what stays on the label. Keep the energy value with the symbol "E" and the allergens printed, and decide whether the full declaration and ingredient list move to the e-label.
- Build the e-label page. Lay out the nutrition table and the ingredient list in a fixed order, in every language of the markets you sell in. Leave out promotional content, tracking and anything that asks the visitor for data.
- Create the QR code. Any QR code that opens the e-label can do the job. A GS1 Digital Link built on the bottle's GTIN also carries the product identity, so the same code rings up at a 2D-ready checkout.
- Put the code on the artwork. Respect the minimum size and quiet zone, keep it clear of capsules and neck labels, and label it so buyers know it leads to the ingredients. See the legibility guide and the dual barcode guide.
- Test the printed proof. Scan it on several phones, check that the page opens in each language, and confirm that no tracking script or cookie banner loads with the e-label.
- Keep it current. When a blend, a treatment or a value changes, update the page for the affected wine or vintage. A dynamic code keeps the same printed symbol while its destination changes.
Transitional rules and enforcement
The Regulation gave producers two years, to 8 December 2023. Wine produced before that date under the previous rules, and aromatized wine products produced and labeled before it, may be sold until stocks run out, without relabeling. Every wine produced since must comply.
Regulation 2021/2117 sets no fines itself. Member States keep non-compliant wine off the market, withdraw it where it is on sale, and set the penalties.
Wine e-labels on the Digital Link platform
Digital Link, the platform behind this site, covers the code and the page:
- A wine and spirits template. The page comes with the sections the category needs.
- Every language from one code. Pages can be translated, and content can change by language and country from the same printed code.
- Built on the GTIN. The platform validates each GTIN and creates the code for your artwork.
- Updates without reprinting. Every link is dynamic, so a new vintage or a corrected value is a page edit, not a new label.
Whatever the tool, check that the e-label page has no marketing or tracking before printing. The Free plan covers 5 codes.
Create your first wine e-label
For other food, see QR codes on food packaging; for how scans are routed, the resolver guide.
Frequently asked questions
Does EU Regulation 2021/2117 require a QR code on wine bottles?
No. It requires the nutrition declaration and the ingredient list, and allows them by electronic means. A producer who prints both in full needs no code; a code helps because a wine label has little room for both in several languages.
What must stay on a wine label if I use an e-label?
The energy value, shown with the symbol "E", and any allergens, such as sulfites. The rest of the nutrition declaration and the full ingredient list can move to the e-label.
Can the e-label page show promotions or collect analytics?
No. The page with the mandatory information must not collect or track user data and must not carry marketing content. Put offers, recipes and shop links on a separate page.
Does the wine e-label have to be a GS1 Digital Link?
No. The Regulation names no code format. A GS1 Digital Link is a practical choice because it carries the bottle's GTIN, so one code rings up at a 2D-ready checkout and opens the e-label on a phone.
Which language must the e-label be in?
A language easily understood by consumers in the country where the wine is sold, under Article 15 of Regulation (EU) No 1169/2011. One code can serve several markets if the page offers each language.
Does the rule apply to spirits, beer or cider?
No. Spirits, beer and cider above 1.2% alcohol remain exempt from both particulars under the general EU food information rules.
