Wine e-label rules: what the EU requires behind the QR code

The short version

• Print the word, not a symbol. Next to the QR code, print a heading that contains the word "ingredients" in the label's language. An "i" alone is not enough.
• Keep the page neutral. No shop, no marketing and no visitor tracking on the page the code opens.
• Keep it online. The page must stay available for as long as the wine is expected to stay fit to drink.

What moved behind the code since 8 December 2023

Regulation (EU) 2021/2117 changed the EU wine rules. Wine produced from 8 December 2023 must show a list of ingredients and a nutrition declaration. The full list and the full declaration may be given "by electronic means", which in practice means a QR code.

Two things stay on the bottle. The energy value must be printed on the label, and it may be shown with the symbol "E". Allergens such as sulphites must also be printed on the label itself.

4 rules from the Commission's Q&A

On 24 November 2023 the European Commission published answers to common questions on these rules (notice C/2023/1190). Four of those answers decide whether an e-label is acceptable.

• Q30: not on your website. The Commission says a winery's own website does not seem to meet the rules. Such sites usually carry sales or marketing content, and they usually track visitors.
• Q35: no tracking, even with consent. No user data may be collected or tracked. The Commission says there are no exceptions, so a cookie banner asking for consent does not help.
• Q38: say what the code opens. A symbol such as an "i" is not sufficient. The label needs a heading with the word "ingredients", as on other food.
• Q40: keep the page for the life of the wine. The page should stay available for at least as long as that kind of wine is expected to stay fit to drink under normal storage.

The Commission also says a link to a winery's online shop counts as marketing (Q37). Different wines may share one site, but each code must open the information for that wine (Q34).

What changed in 2026

Regulation (EU) 2026/471 of 24 February 2026 amends the rules again. It lets the Commission set a common symbol to replace the words next to the code, through a later act. It also adds the terms "alcohol-free" and "0.0%", which apply from 19 September 2027, and it exempts wine made only for export from some labelling points.

As of November 2026 we found no act that sets that common symbol. Until one exists, keep printing the word.

Mistakes to avoid

• The "i" on its own. In September 2025 Wines of Romania reported that producers had to reprint labels that showed a QR code without the word for ingredients.
• Analytics on the page. Scan counts, tracking pixels and analytics scripts collect user data, which Q35 rules out.
• A page that expires. Some services switch pages off when a trial or subscription ends. A printed bottle cannot be updated, so check what happens to the page if you stop paying.
• A shared marketing page. Put the ingredients and nutrition on a page of their own, not under a product page or a shop.

Sources

• Regulation (EU) 2021/2117, amending Regulation (EU) No 1308/2013, Article 119. Official Journal L 435, 6 December 2021. eur-lex.europa.eu/eli/reg/2021/2117/oj (supports)
• European Commission, Commission notice on questions and answers on the application of the EU rules on the labelling of wine, C/2023/1190, 24 November 2023, questions 30, 34, 35, 37, 38 and 40. eur-lex.europa.eu (supports)
• Regulation (EU) 2026/471 of 24 February 2026, amending the wine labelling rules. eur-lex.europa.eu/eli/reg/2026/471/oj (context)
• Wines of Romania, report on labels reprinted without the word for ingredients, September 2025. (context)

Other views

Trade bodies asked the Commission in late 2023 to suspend its reading that the word "ingredients" must appear next to the code, while the rules were being discussed. Regulation 2026/471 answers part of that request by allowing a future common symbol. Until that symbol is set, the Commission's reading in Q38 is the one inspectors use.

This guide explains the EU rules in plain words. It is not legal advice. National authorities check the labels, and some countries add their own rules. If we have misread a rule, tell us and we will correct it.