EU Wine E-Label Regulation: The Complete Guide for Wineries and Importers

Since December 8, 2023, all wine produced or imported in the European Union must include digital labelling that provides consumers with a complete list of ingredients and nutritional information. This requirement stems from EU Regulation 2021/2117, which amended the Common Market Organisation (CMO) regulation for wine.

If you produce, import, or distribute wine in the EU, this regulation directly affects you. Here's what you need to know — and how to comply.

What the Regulation Requires

The amended regulation mandates that wine labels must disclose:

Full ingredients list — including all additives, fining agents, and processing aids used in production
Nutritional declaration — energy value (kJ/kcal), fat, saturates, carbohydrates, sugars, protein, and salt
Allergen information — particularly sulphites, milk, and egg derivatives

Crucially, the regulation allows this information to be provided electronically — via a QR code on the physical label that links to a digital label. The QR code approach has become the standard because it's impractical to fit all required information in the 24 EU languages on a physical wine label.

Key Deadlines

December 8, 2023 — Regulation applies to all wines produced after this date
Wines produced before December 8, 2023 — May continue to use old labels until stocks are exhausted
Ongoing enforcement — Member states are responsible for enforcement, with varying levels of active checking

What a Compliant Digital Label Looks Like

A compliant e-label must meet several requirements:

Content requirements: The digital label must display the full ingredients list and nutritional declaration. It must be available in the language(s) required by the member state where the wine is sold. For wines sold across multiple EU markets, multi-language support is essential.

Technical requirements: The digital label page must not contain any marketing or sales material. The EU has been clear that the e-label is for consumer information only — it cannot be used as a marketing landing page. It must also be accessible (WCAG compliance is recommended) and mobile-friendly.

Data protection: The e-label must not track consumers or collect personal data. No cookies, no analytics pixels, no email capture forms. This is a strict interpretation that some member states are actively enforcing.

How QR Digital Labels Work

The typical compliance flow for wineries looks like this:

Enter your wine data — ingredients, nutritional values, allergens, vintage, grape varieties
Generate a QR code — linked to a stable URL that displays the digital label
Print the QR code on your physical label alongside the standard label elements
The consumer scans the QR code with their phone and sees all required information in their language

At WORQABLE, we built QR Digital Label specifically for this use case. It handles multi-language labels (24+ EU languages), generates compliant QR codes, and ensures the digital label page meets all EU requirements — including the no-marketing and no-tracking rules.

Common Compliance Mistakes

Linking to your website instead of a dedicated label page. If your QR code points to a product page with "Buy Now" buttons and newsletter signups, you're not compliant.

Missing allergen declarations. Even if you don't use sulphites above the threshold, you need to declare it if they're present. The same applies to egg and milk derivatives used as fining agents.

Not supporting required languages. If you sell wine in Germany, the label must be available in German. If you sell in Belgium, you need French, Dutch, and potentially German.

Using dynamic QR codes that change URL. Some QR code generators use redirect URLs that can break. The EU expects the QR code to consistently lead to the correct information.

Cost of Non-Compliance

While enforcement varies by member state, the consequences can be significant: product recalls, fines, and import refusal at borders. Italian and French authorities have been particularly active in enforcing the new requirements.

More practically, major retailers and distributors are increasingly requiring proof of e-label compliance as a condition of listing your wines.

Getting Started

If you're a winery or importer looking to comply with EU 2021/2117, the process is straightforward with the right tool. QR Digital Label lets you set up compliant e-labels in minutes — enter your wine data, generate the QR code, print it on your label.

For questions about the regulation or how it applies to your specific situation, get in touch.