Two things became mandatory on EU wine labels on 8 December 2023: a list of ingredients and a nutrition declaration. The change came from Regulation (EU) 2021/2117, which amended the common market organisation regulation (EU) No 1308/2013 and brought wine in line with the food information rules that everything else on a supermarket shelf had followed for years.
The part that causes the most confusion isn’t whether to declare — it’s where. Most of the new information can sit on a digital label reached by scanning a QR code. Some of it cannot. Get that split wrong and you have a compliant-looking bottle that isn’t.
Which of your wines are affected
The trigger is the harvest, not the bottling date or the sale date.
Wine produced from grapes harvested from 8 December 2023 onwards must carry the new particulars. Wine produced before that date, under the previous rules, may generally continue to be placed on the market until stocks are exhausted.
In practice this means most producers are running two label versions in parallel — older vintages on the old format, new vintages on the new one — and will be for as long as the back catalogue lasts. It is worth tracking which SKUs are on which format rather than discovering it at a customs check.
What must stay printed on the bottle
Three things cannot be moved to a digital label:
The energy value. The nutrition declaration may be given off-label, except the energy value, which has to be on the physical label. It can be expressed in a shortened form using the symbol “E” followed by the value in kJ and kcal per 100 ml.
Allergens. Substances causing allergies or intolerances — in wine, most commonly sulphites, and egg or milk derivatives used as fining agents — must always be declared on the physical label. There is no electronic alternative for these.
Everything that was already mandatory. Designation of origin, actual alcoholic strength, nominal volume, provenance, bottler, allergens, lot number. The new rules add to that list, they do not replace it.
What can move to the e-label
The full nutrition declaration — energy plus fat, saturates, carbohydrate, sugars, protein and salt, expressed per 100 ml.
The list of ingredients — grapes, plus any additives and processing aids still present in the final product.
Both may be provided by electronic means, identified on the bottle by a symbol or a QR code, as long as the requirements below are met.
Calculating nutrition values
You do not need a laboratory analysis for every wine. Nutrition values may be established by calculation, using generally established and accepted data — which for most still wines means deriving energy from alcohol and residual sugar rather than sending samples away. Analysis is an option, not an obligation.
The rules an e-label must follow
This is where a homemade solution usually fails. The page behind the QR code is not a landing page — it is a regulated surface, and it comes with conditions:
- No marketing or commercial information. The page presenting the mandatory particulars must not display it alongside promotional content. A QR that lands on your shop, your newsletter signup, or a page with a “Buy now” button is not compliant.
- No user data collection or tracking. No analytics that profile the scanner, no cookies used for tracking, no login wall.
- Direct access. The scan must reach the information itself, not a homepage the consumer then has to navigate.
- Available in the right language. Mandatory particulars must be in a language easily understood by consumers in the member state where the wine is marketed. Exporting to four countries means the e-label needs to answer in four languages.
- It has to keep working. A URL printed on 30,000 bottles has to resolve for as long as those bottles are on shelves. Whatever you use, make sure the link outlives the marketing site redesign.
A practical checklist
Before you sign off a new label:
- Is the wine from a harvest on or after 8 December 2023?
- Is the energy value printed on the physical label?
- Are allergens printed on the physical label?
- Is the QR code or symbol clearly identifying the electronic information?
- Does the e-label page carry the ingredients and the full nutrition table?
- Is that page free of marketing content and tracking?
- Does it resolve in every language you sell into?
- Have you recorded which SKUs are on the new format?
Where this usually goes wrong
The two failures we see most often are the same every time. The first is treating the e-label as a marketing asset — a beautifully designed page with the estate’s story, an instagram link, and the nutrition table somewhere near the bottom. The second is a QR code pointing at a URL nobody owns the renewal for.
Both are avoidable, and neither is really a labelling problem. They are data problems: the same wine facts have to be structured once, then published in several places and several languages without drifting apart.
That is exactly what Drinksbase does — structured wine records that generate a compliant e-label page and a QR code, translated on demand, with the public page kept clean of anything that shouldn’t be on it.
This article is general guidance, not legal advice. The authoritative text is Regulation (EU) 2021/2117 and Regulation (EU) No 1308/2013 as amended; national authorities may add their own requirements. Check with your competent authority or a compliance advisor before committing a label to print.
