QR Codes on Wine Bottles
Since December 2023, EU Regulation 2021/2117 requires a nutrition and ingredient e-label reached by a QR code on the back label. Here is exactly what stays on the bottle, what goes behind the QR, the strict no-tracking rule, and how to update every vintage without reprinting.
What is a wine e-label?
A wine e-label is a digital page - the wine's full ingredient list and nutrition declaration - reached by scanning a QR code printed on the bottle's back label. Since 8 December 2023, EU Regulation 2021/2117 requires every wine and aromatised wine sold in the EU to provide this information, and lets the full detail live behind the QR instead of crowding the physical label.
Wineries want two things from that code: to be compliant, and to never reprint a label when a vintage's values change. This guide covers what the law requires, what must stay printed on the bottle versus what can move behind the QR, the strict no-marketing and no-tracking rule for the e-label page, and the print and scan specifics for curved glass. It is part of our guide to QR codes on every surface.
The EU wine e-label regulation (2021/2117)
Regulation (EU) 2021/2117 amended the EU wine rules so that, since 8 December 2023, every wine and aromatised wine placed on the EU market must carry a nutrition declaration and a full list of ingredients. The regulation explicitly allows the full detail to be provided by electronic means - a QR-code e-label - so the physical label stays readable.
- Effective date: applies to wine produced, or imported into the EU, from 8 December 2023 onward.
- Grandfathering: wine produced or imported before that date may be sold until stocks run out - no relabelling of older vintages.
- Export exemption: wine produced solely for export outside the EU is exempt.
- UK: after Brexit the UK is not bound by the EU e-label rule; follow each destination market's own rules.
On the bottle vs behind the QR
Per Article 119 and the Commission's 2023 guidance. The QR, the energy value, and the allergens must sit together in the same field of vision.
| Information | Physical label | QR e-label page |
|---|---|---|
| Energy value (kJ + kcal per 100 ml) | Required - the symbol E is allowed | Not allowed - must be printed |
| Allergens (sulfites, milk/egg fining agents) | Required, on or attached to the pack | Not allowed - must be printed |
| ABV, category, provenance, bottler, lot, net quantity | Required | No |
| Full ingredient list (descending weight) | Optional | Allowed |
| Full nutrition table (fat, carbs, sugars, protein, salt) | Energy must stay; the rest may move | Allowed |
What the e-label page must - and must not - contain
This is the rule competitors bury, and it is the most important one. The wine e-label page reached by the regulatory QR:
- Must contain only the legally required ingredient list and nutrition information, presented clearly, the way a label would.
- Must not contain any sales or marketing - no winery promotion, no buy-now, no shop links, no brand storytelling.
- Must not track the person who scans it - no analytics, no cookies, no IP logging, no profiling. Because no personal data is collected, the compliant e-label needs no GDPR consent banner.
In other words, the scan that satisfies the law cannot double as a marketing or retargeting touchpoint. If you want to tell your story, share pairings, or measure engagement, that belongs on a separate QR code elsewhere on the bottle - never on the regulated back-label e-label.
Multilingual: one wine, many markets
The e-label information must be given in an official EU language the consumer in each market understands. A Tempranillo sold in Germany, France and the Netherlands needs its e-label readable in German, French and Dutch. Many producers translate into all 24 official EU languages and serve the right one automatically by the scanner's language or location. A single-language page does not satisfy the rule across multiple markets.
Static or dynamic? Why wine needs a dynamic QR
The regulation does not dictate a code type, but wine has a problem a static code cannot solve: final lab values often arrive after the labels are already printed, and each vintage is legally a new wine. A static code bakes the destination in forever; a dynamic QR code keeps a short redirect you control, so you can fill in or correct the nutrition and ingredient data - and adapt as the rules evolve - without reprinting a single label.
Two practical rules: give each wine and each vintage its own QR (one shared code across several wines is not compliant), and treat the dynamic redirect as the permanent address the printed bottle points to. For the deeper trade-off, see static vs dynamic QR codes.
Your 2024 e-label must still resolve in 2034
Wine sits in cellars and on shelves for years, sometimes decades. A wine QR that expires - or that stops resolving when an annual subscription lapses - is a compliance failure waiting to happen. Several niche e-label tools are yearly subscriptions where letting the plan lapse can break the link on bottles already sold.
QRLynx dynamic codes never expire and have no scan cap, and the free plan includes them with no credit card. The printed bottle is permanent, so the link behind it must be too. For the regulatory scan itself, point the code at a clean, tracking-free e-label page, as the compliance note above explains.
Beyond compliance: a separate marketing QR
The regulated e-label cannot carry marketing or analytics - but your bottle can still earn engagement, just from a different code. A second QR, placed away from the regulatory e-label, can open the wine's story, food pairings, a vineyard video, a wine-club sign-up, or a reorder page. That one is yours to make dynamic and to measure with scan analytics. Keep the two jobs - legal compliance and marketing - on two separate codes, and both stay clean. Restaurants and wine bars extend the idea to the table; see QR codes for restaurants.
Printing a QR that scans on curved glass
A wine bottle is the hardest QR surface most producers will ever print on: it is curved, often dark glass, and scanned under dim cellar or bright retail light.
- Place it on the flattest area of the back label, away from the bottle's sharpest curve.
- Size up for the curve - aim for at least 2-2.5 cm (1 in); curvature shrinks the readable area, so do not go minimal.
- Use error correction Q or H so the code tolerates the curve's distortion and any label wrinkle.
- Matte, not gloss. Gloss varnish and foil reflect light and kill scans; keep high contrast, ideally dark on light.
- Keep a four-module quiet zone of clear space around the code.
For the full sizing math, see our QR code print size guide and QR codes on labels.
How to add a compliant wine e-label QR
Five steps to a code that satisfies Regulation 2021/2117 and updates with every vintage.
Generate one dynamic QR per wine and vintage
In the QR code generator, create a dynamic code for each wine and each vintage - never one shared code across wines. Dynamic lets you edit the linked data later without reprinting.
Build a neutral e-label page
The destination must show only the full ingredient list and nutrition declaration, in the languages of your markets, with no marketing content and no cookies, analytics, or user tracking.
Keep energy and allergens on the physical label
Print the energy value (kJ + kcal per 100 ml) and allergens such as sulfites on the bottle itself, in the same field of vision as the QR code.
Print the code for curved glass
Place the QR on the flattest part of the back label at 2-2.5 cm (1 in) or larger, error correction Q or H, matte finish, high contrast, with a four-module quiet zone.
Test, then update values without reprinting
Scan a finished bottle to confirm it resolves to the correct e-label. As final lab results arrive, edit the linked nutrition and ingredient data in your dashboard - the printed bottles update automatically.
Are QR codes required on wine in the US?
No. The EU rule does not apply in the United States. The TTB does not require a nutrition or ingredient QR code on wine; some US producers add one voluntarily, often a separate marketing QR for the wine's story, pairings, or club sign-up. If you export to the EU, though, the EU e-label rules apply to those bottles - so check the requirements of every destination market.
Wine bottle QR code FAQ
The EU regulation, what goes where, tracking, dynamic vs static, and curved-glass scanning.
Are QR codes mandatory on wine bottles in the EU?
A QR code is not literally mandatory, but the information it carries is. Since 8 December 2023, EU wine must show a nutrition declaration and full ingredient list, and the full detail may be provided electronically via a QR e-label rather than printed in full on the bottle - which is why nearly all producers use one.
What does EU Regulation 2021/2117 require on a wine label?
A nutrition declaration and a full list of ingredients for wine produced or imported into the EU from 8 December 2023. The energy value and allergens must stay printed on the bottle; the full ingredient list and nutrition table may move behind a QR-code e-label.
What must be on the physical label vs behind the QR code?
On the bottle: the energy value (kJ + kcal per 100 ml), allergens such as sulfites, plus ABV, category, provenance, bottler, lot and net quantity. Behind the QR: the full ingredient list and the complete nutrition table.
Can the energy value go behind the QR code?
No. The energy value must be printed on the physical label, in both kJ and kcal per 100 ml (the symbol E is allowed). Only the rest of the nutrition table and the full ingredient list may move behind the QR.
Can my wine e-label page contain marketing or a shop link?
No. The regulated e-label must contain only the legally required ingredient and nutrition information - no sales or marketing content. Put your story, pairings, or shop on a separate QR code elsewhere on the bottle.
Can I track or collect data when someone scans my wine e-label?
No. The compliant e-label page must not track users - no analytics, cookies, IP logging, or profiling. Because no personal data is collected, it needs no GDPR consent banner. Scan analytics belong on a separate marketing code.
Should I use a static or dynamic QR code on my wine label?
Dynamic. Lab values often finalize after labels are printed, and the rules may evolve - a dynamic code lets you update the linked data without reprinting. Give each wine and vintage its own code.
Do I need a separate QR code for each wine and vintage?
Yes. Each vintage is legally a new wine with its own ingredients and nutrition values, so each needs its own product-specific e-label. One shared code across several wines is not compliant.
Does the wine e-label have to be multilingual?
It must be readable in an official EU language understood by the consumer in each market you sell to. Selling across several EU countries means serving the e-label in each of those languages.
Are QR codes required on wine bottles in the US?
No. The US TTB does not require a nutrition or ingredient QR on wine. Some producers add one voluntarily. If you export to the EU, the EU e-label rules apply to those bottles.
Do QR codes scan reliably on curved wine-bottle glass?
Yes, with care. Place the code on the flattest part of the back label at 2-2.5 cm or larger, use error correction Q or H, a matte finish, high contrast, and a four-module quiet zone, then test-scan a finished bottle.
Do older vintages bottled before December 2023 need an e-label?
No. Wine produced or imported into the EU before 8 December 2023 is grandfathered and may be sold until stocks run out, with no relabelling required.
Create your wine bottle QR codes
Make your wine codes dynamic so you can update every vintage without reprinting, and generate one free per wine - they never expire. See also QR codes on labels, packaging, and the full QR codes on every surface guide.
Sources: Regulation (EU) 2021/2117; Commission Notice C/2023/1190 (wine labelling Q&A). This guide is general information, not legal advice - confirm the requirements for each market you sell in.
By Ahmad Tayyem · Last updated: