Wine e-label: what has to be on the bottle

What must stay printed on the bottle

Two items cannot move behind the code. The energy value, marked with the letter "E", has to appear on the package, and so do the allergens, in practice the sulphites declaration. Everything else in the nutrition declaration, and the full ingredient list, may be provided electronically.

For a label check this is the first thing to verify, and it is the most common defect: a batch printed with the full nutrition table on the website and no energy value on the bottle. The code resolves, the data is complete, and the label still fails.

• Printed: energy in kJ and kcal per 100 ml, the "E", and the allergen statement
• May be digital: fat, saturates, carbohydrate, sugars, protein, salt, and the ingredient list
• Wine under 10 percent alcohol: the date of minimum durability may also be electronic
• The printed energy value is required even when the rest of the table is digital

What may not sit behind the code

The electronic label may not carry sales or marketing content, and it may not collect personal data from the person scanning it. A shop link, a newsletter form or an analytics pixel on the same page is a compliance risk that buys nothing.

In practice this rules out most redirect services: a short link whose whole purpose is to count scans is collecting data on the page the regulation is talking about. A code that points directly at a page you control, with no counting, is the cleaner construction.

One code per wine, and the price-list exception

Each wine needs its own destination, because ingredients and values differ between wines. The regulation allows a shared code where a price list with an ordering function covers several wines, pointing at a page that carries the information for all of them. That is a narrow exception, not a shortcut for an entire range.

For an importer holding several producers, this is where batches get mixed up: a shared page for a range is fine for the list, and wrong for the individual bottles.

How long the destination has to work

The information has to stay available for as long as the product is on the market. That is longer than most campaign pages live, and it is the part that fails quietly: a batch printed in 2024 scans fine in 2024 and dead in 2027.

Before accepting a label, check that the destination is a permanent address you or the producer controls, without a login, without a redirect service and without an expiry. A code is only as durable as the page behind it.

Print checks before a batch runs

On a 100 mm label, 15 mm is the floor for a code and 18 mm is comfortable, with a quiet zone of at least four modules. Error correction level Q or H survives the handling a bottle gets in a cold chain.

The code must be darker than its background. A light code reversed out of a dark label photographs well and fails in a cellar or a restaurant with dim lighting. Print, then scan the actual material with three devices before the run, not the PDF.

• Minimum 15 mm, better 18 mm, on a 100 mm label
• Error correction Q or H, quiet zone of four modules
• Never inverted, no gloss varnish over the code
• Test on the real substrate under shop or cellar lighting