What the electronic wine label has required since December 2023
Since 8 December 2023, wine marketed in the European Union has had to show the list of ingredients and the nutrition declaration. Regulation (EU) 2021/2117 amended Article 119 of Regulation (EU) No 1308/2013, the common organisation of the markets, and opened the way to giving that information electronically. In practice the winery can put the detail behind a QR code, the electronic label or e-label, as long as the other compulsory particulars stay on the physical label and the link is not confused with a marketing code.
This guide sums up who is obliged, which wines stay outside the rules while stocks last, and what cannot leave the glass. It does not replace the official text. The reference is Commission communication 2023/C 1190.
Who it applies to
The obligation covers the wine products in Annex VII of the CMO Regulation that are marketed in the EU (wine, sparkling, semi-sparkling, liqueur wine, and the other categories in that annex) and aromatised wine products, which the same 2021 reform also brought under ingredients and nutrition.
There is no threshold by size of winery. A two-hectare holding that sells bottles in a Member State is as obliged as a large cooperative. The person responsible for the information is whoever markets the wine: the producer when the wine is from the EU, and the importer when it comes from a third country. If you bottle for a client who puts their brand on it, write down who maintains the e-label. The printed code has to keep resolving while those bottles are on sale.
The date that matters is not the date on the label, and it is not the date of the customer’s order. The Commission distinguishes wines “produced” before 8 December 2023. Those wines may keep being marketed under the previous rules until stocks run out. “Produced”, for a still wine, means it has already reached the alcoholic strength and the acidity required for its category, not that the grapes have been harvested. A 2023 base that was not yet wine on 8 December is not exempt because of the vintage year.
For sparkling wine the cut-off is stricter. The product is considered produced when the second fermentation has taken place and it meets the pressure and strength requirements. Making the base wine, or preparing the tirage liqueur, before that date is not enough. A cava or a crémant whose prise de mousse is after 8 December 2023 falls under the obligation, even if the grapes are from 2023. The Commission note said it plainly: the 2024 harvest is born inside the new rules, and earlier stock is sold off under the old ones.
What can go on the QR, and what stays on the bottle
The list of ingredients and the full nutrition declaration may appear on the physical label or be provided by an electronic means identified on the package. The usual path is the QR, because the back label has no room for a nutrition table in several languages.
The energy value, in kJ and kcal per 100 ml, has to be visible on the physical label if the full nutrition is on the QR. It may use the symbol “E”, which avoids translating the word “energy”. Exporting wineries write it as “E 100 ml: … kJ / … kcal”. If you print the whole table on the bottle, the nutrition QR is not required. Many wineries avoid that, because the table does not fit and each market asks for its own language.
Allergens stay on the physical label, with the same logic as always: sulphites, and egg or milk if they have been used as fining agents and are still present. Putting them only inside the QR does not comply. The QR does not replace the allergen statement. It completes it.
The code has to be in the same field of vision as the other compulsory particulars on that face: category, PDO or PGI where relevant, alcoholic strength, provenance, bottler, and net content. It is not acceptable to hide it on the capsule, or to confuse it with a promotional code. The word “ingredients” has to identify it, and the destination page cannot be the shop or a form. The Commission leaves marketing, and the collection of user data, out of that link.
What the declaration contains
Per 100 ml, the declaration follows the order of Regulation (EU) No 1169/2011: energy, fat, saturates, carbohydrate, sugars, protein, and salt. In a dry wine almost everything is zero except the energy. The figure comes from the laboratory (strength, sugars, and acidity) with the conversion factors from food information law, not from a variety average. We calculate that step. You can also paste the value the laboratory has already given you.
The list of ingredients goes in descending order of weight. Additives are named by their category and their name or E number, and the whole cellar sheet is not copied across. Bentonite, enzymes, or nutrients that do not remain are not an ingredient for labelling purposes. The usual mistake is to dump the technical sheet without that filter.
The language is that of the Member State where the wine is marketed, not “all 24 at once on every bottle”. A winery that only sells in Spain can present the e-label in Spanish. As soon as it crosses into France, Germany, or Portugal, the consumer in that market has to be able to read it. Translating into the 24 official languages covers any EU destination and avoids rebuilding the QR every time an importer opens a new country. The “E” symbol for energy, on the bottle, was made precisely so the glass does not depend on language.
How to check a reference before you print
It is worth checking each wine against a short list before you send the PDF to the printer.
- Confirm whether that lot was “produced” after 8 December 2023. Earlier stock is documented and sold off under the old rules.
- Leave the energy value per 100 ml, in kJ and kcal, and the allergens, on the back label.
- Check that the QR falls in the same field of vision, and that it is readable next to it that the ingredients are there.
- Open the link on a phone. The record has to load on its own, in the language of the market, with no form and no shop.
- Keep the analysis bulletin. If the wine is sparkling, do not treat it as exempt only because the base wine is from 2023.
Our QR is dynamic: the printed address does not change when you correct a sugar, an additive, or a language. The back-label plate lives for several years, and the analysis of a lot does not. The published price is €50 a year, with unlimited QR codes.
If you want to see a record, sign-up is at app.vinoveo.com/login. If the QR codes are already on another platform, the path is the migration page. Pointing a code that is already printed, without reprinting, is possible only when that QR is dynamic and can be redirected. A static QR still has to be reprinted on the next run.
