electronic tag legislation

Legislation/Guidance on electronic labelling (digital wine labelling using qr-codes)

Χωρίς κατηγορία

Requirements for the EU wine label from 8 December 2023:

A guide for wineries.

What the legislation provides for electronic tagging: According to European Regulation (EU) 2021/2117, in order to provide a higher level of information to consumers, the mandatory indications under Article 119 of Regulation (EU) No 1308/2013 should include

  • a nutrition declaration, and
  • list of ingredients.

However, producers should have the option to limit the contents of the nutrition declaration on the package or on a label attached to it to the energy value only and to make the full nutrition declaration and list of ingredients available by electronic means, since they avoid at the same time the collection or monitoring of user data and do not provide information for the purpose of marketing. However, the choice not to provide a full nutrition declaration on the package or on a label attached to it should not affect the existing requirement for the label to indicate substances causing allergies or intolerances.

Disclaimer

This text is an interpretation of the existing legislation and a collection of reliable legal opinions regarding the nutrition declaration and the declaration of ingredients for wine. Get legal advice from a professional for the most up-to-date information. This information is also subject to change.

Table of Contents

What are the requirements for mandatory indications on electronic labels?

For any wine sold in the EU, it must be provided:

  • List of ingredients
  • Nutritional information

Attention: If the wines can be ordered directly from the end consumer in a price list, brochure, online store, etc. (eg via e-shop, by phone, in writing, by e-mail), the list of ingredients and nutritional information must also be provided at the time of purchase.

The regulation applies to wines produced after 8 December 2023 for sale in the EU. 

All wines with a vintage of 2024 and beyond must comply.

Information on the use of electronic labels (QR codes)

The full list of nutrition table ingredients can be made available via an e-label – a QR code on the printed label that links to a mobile web page.

According to the regulation, there are certain conditions that electronic tags should meet

Ability to translate.

Labels should be able to be translated into the languages of any country you may sell your products to using the official EU translations.

Label lifetime

Your electronic labels must remain available for as long as the wine is expected to remain fit for consumption under normal storage. The presence and accuracy of the information is the responsibility of the food information business operator, in accordance with Article 8(2) of the FIC Regulation

Ensuring privacy

Collection of user data is not allowed. This means no tools like Google Analytics. (Only location collection is allowed for the delivery of the appropriate language.)

Sales – marketing

Electronic labels are not allowed to display other information related to the sales and marketing of the product

File downloads

There must be no PDF or other file downloads for the consumer to access the e-label content

No navigation

The user should not click to go to another information page other than the language selection.

What if I just put the information on my website?

It is allowed, however you just need to meet all the above conditions. For most producers, it’s not feasible and/or more expensive than using a third-party solution, as it will require building a separate website infrastructure from your marketing website and online store.

Advantages of QR codes (electronic labels)

QR codes have many advantages:

  • First, the QR code offers a space-saving solution without compromising the label design.
  • Second, QR codes are dynamic, meaning that the information behind the QR code can be updated at any time. This is particularly important as it is common for the final bottled wine data to often not be available when the labels are printed. Thanks to dynamic QR codes, however, this data can be added when the product goes on sale.
  • Third, QR codes also allow for easy integration in online stores into price lists or brochures

Get started with e-tags

You can create 3 free e-tags today (no commitment or credit card required)

Follow the link below to create 3 free e-tags (no commitment or credit card required). 

Wine e-labels

Select the free registration to enter the platform and then select the use of the free service “FREE”

This process will guide you through creating a compliant electronic label.

There are seven main sections that you will complete to create the electronic label. Not all are mandatory. You can fill in only the mandatory information required by the specific regulation or expand to additional information such as e.g. technical characteristics, sustainability information, packaging, recycling instructions (which are necessary for certain markets), commercial representative, etc.

It is recommended that you create a new e-tag for each:

  • new product
  • different volume of product
  • new crop product

Caution: once an electronic tag is on the market, you should not update it unless the information needs to be corrected. For example, do not use the same e-label for the new crop by simply updating the information on the label of the previous crop. This will result in non-compliance with the older vintage label.

List of ingredients

We use official EU ingredients in our ingredient selector. The platform will format your listing to comply with the law. For example they will appear intensively allergens to differentiate them from the rest of the ingredients text

When choosing ingredients, there are a few rules to keep in mind.

Regarding the presentation of the catalog:
  • The list of ingredients is preceded by a title containing the word “ingredients”.
  • The list lists the ingredients in descending order of content by weight, as recorded at the time of their use in the preparation of the food. Ingredients used in less than 2 % in the final product may be listed in a different order after the other ingredients.
  • Ingredients are listed by their specific name, with the exceptions provided for in the FIC Regulation and Delegated Regulation (EU) 2019/33 (e.g. “grapes” listed as raw material).
  • The identification of additives in the list of ingredients must be done by the name of their functional category, followed by their specific name or, as the case may be, by the E number.
  • Article 48a paragraph 5 of the delegated regulation (EU) 2019/33 provides for the possibility to list the additives belonging to the categories “acidity regulators” and “stabilizers” (which are similar) to be substituted for each other by using the expression “contains… and/or”, followed by a maximum of three additives, when at least one of them is contained in the final product.
  • It is mandatory to list any ingredient or technological aid (processing aid) that causes allergies or intolerances and is used in the production of the product and is still present in the final product, even in a modified form.
  • If several wines are blended, it is recommended to list all ingredients used in total (eg tartaric acid or sulfur dioxide only once in the list).
  • Ingredients must be listed in descending order of weight as they were used in the preparation of the food. Components that make up less than 2% of the final product may be listed in any order, after the other components.
  • Some additives used as packaging gases (carbon dioxide, argon and nitrogen) have the main purpose of displacing oxygen during the bottling of wine products but do not become part of the consumed product. In these cases, you can choose to add “Bottled in a protective atmosphere” or “Bottling may be done in a protective atmosphere”.

Nutritional declaration

You can use the energy calculator we provide you through the platform or enter your own data manually.

To calculate the energy it is necessary to fill in some data such as alcohol percentage, residual sugars, total acidity and glycerin. The calculation is based on the official energy conversion factors of the European regulation.

For wines with a sugar content below 100 g/l (usually all wines except sweet wines), a tolerance of 2 g/100 ml (equivalent to 20 g/l) is allowed for the sugar/carbohydrate declaration.

Fat, saturated fat, protein and salt are contained for almost all wines only in negligible amounts, as long as good production practices are followed.

You have three options for negligible amounts of fat, saturated fat, protein and salt. You can enter “0” as the value, you can choose the statement “contains negligible amounts” or you can choose to display a simplified table for negligible amounts (fat, protein, salt).

More information on negligible amounts can be found in section 6, table 4 of the EU guidance documents on nutrition labeling for EU 1169/2011.

You are responsible for declaring values that exceed these tolerances, however many associations and legal experts state that standard wines do not require additional testing.

Packaging information

In Italy you are required to indicate the material recycling code on your packaging and provide waste collection instructions according to Decreto legalivo April 3, 2006, n. 152 .  

This can be done entirely through the e-label by searching and selecting the materials you use.

Natural wine label

You should add three items to your back label:

  • The energy in kj and kcal in the form: 100 mL: E= XXX kJ/ XXX kcal. It is important not to use capital letters when writing kJ and kcal.
  • The presentation of a QR code should be clear to consumers regarding its content, i.e. the mandatory information presented by electronic means. General indications or symbols (such as “i”) are not sufficient to meet the requirements of this provision. As stated in Article 18(1) of the FIC Regulation, a heading (text) must be used next to the QR code that clearly indicates the purpose of the QR code. This text must contain the word ‘Ingredients’. The suggestions are to use the expressions: “components” or “ingredients and nutritional values” or “ingredients/nutritional values”. The expression “components” it can be written in any EU language, however if the label is say in English, it would be better to write it in English as “ingredients”.
  • Where the nutrition declaration and/or the list of ingredients are provided by electronic means, the link (QR code or similar code) to the nutrition declaration and/or the list of ingredients must be presented on the label in the same visual field as the other mandatory indications
  • When the full list of ingredients is provided by electronic means, the substances causing allergies or intolerances must be presented on the package or on the affixed label, but not necessarily in the same field of view as other mandatory information (the derogation of Article 40(2) of the ‘ Regulation (EU) 2019/33 authorization).

The QR code.

  • Size: According to international standards (ISO/IEC 15415) the QR code must be at least 11.49 mm x 11.49 mm. Then there should be an empty margin to bring the overall size to 14.66 x 14.66 mm.
  • It should have high contrast, ideally black on white
  • You can have two QR codes, one for marketing, but there should be no confusion as to which is which.

For all wine products that have undergone de-alcoholization treatment and have an actual alcoholic strength by volume of less than 10%, it is appropriate to indicate the date of minimum durability on the physical label.

Useful information:

Wine Legislation: Mandatory Indications of Wine Products based on EU Legislation and National Legislation

Standard values for fat, protein and salt in the nutrition declaration for wines

Frequently asked questions (FAQ)