Can I use only the QR code and remove the ingredients from the label?

Yes. The list of ingredients and the nutrition table can go only in the QR code. But the energy value, the allergens («Contains sulphites») and the word «Ingredients» next to the code stay on the paper.

So what do I gain by moving it to the QR code?

Room. The list of ingredients and the nutrition table, in every language where you sell, do not fit on a back label.

Can I link my shop or website from the ingredients QR code?

No. The Commission considers any link to the winery's website or shop to be marketing.

Can I know how many people scan the legal QR code?

No. Data of the person who scans cannot be collected, not even with their consent.

Is an «i» next to the code enough?

No. Today it has to say «Ingredients». Once the Commission publishes the common pictogram, the symbol will do.

Do I have to relabel the wines I already had?

No, if they were produced and labelled before 8 December 2023: they can be sold until stocks run out.

Is signing the e-label mandatory?

No. Signing it is your proof for an inspection, not a legal requirement.

The wine e-label and QR code: what is mandatory and what is not

Guide updated on 15 October 2026. Each point gives, in brackets, the rule it comes from; all of them are listed at the end, with a link to the official text.

Since 8 December 2023, wine has to say what it contains and what it provides, like any other food. And for the first time, part of that information can go in a code on the bottle instead of on the paper. Here is what is mandatory, what is forbidden and what is optional, with no small print.

What Europe requires

Europe requires wine to state its ingredients and its nutrition declaration. Until now wine was an exception; not any more.

The rule comes from the EU wine regulation (Regulation (EU) No 1308/2013, from 2013, still in force). In 2021, ingredients and nutrition information were added to it (Regulation (EU) 2021/2117), and the obligation has applied since 8 December 2023. So, in this guide, «Article 119» means the article of the 2013 regulation as amended by that reform.

What is new is where that information can go. A bottle label has little room, so the rule allows part of it to go on an electronic label (e-label): a printed QR code that, when scanned, leads to a page with the data.

That page is not a winery website or a sales page. It is a legal document, and that is why it has rules of its own.

It applies to wines produced from 8 December 2023. Wines already made and labelled before that date can be sold until stocks run out (Regulation (EU) 2021/2117, Articles 5(8) and 6). A wine counts as «produced» once it meets the requirements of its category; a sparkling wine, after the second fermentation (European Commission, C/2023/1190, question 4).

A real back label, item by item

This is the back label of El Mas de l'Avi 2024, our demonstration wine (the winery is fictitious; the data come from its record). It is in Spanish because that is the language required on labels in Spain. On the left, what is printed. On the right, what opens when you scan the legal QR code.

The QR code does not replace the label. It only takes two things off it: the list of ingredients and the nutrition table. Everything else stays printed.

Legal QR page of El Mas de l'Avi 2024: bottle photo, ingredients (grape; sulphites), nutrition table per 100 ml, bottler, pictograms and recycling. — Mandatory on every wine
1Designation of originWith its name. If it is there, the category («wine») may be left out.1308/2013, Art. 119(1)(b), 119(2) and 119(3)
2Alcoholic strengthIn units or half units, with «% vol». Tolerance of 0.5% vol.119(1)(c) · 2019/33, Art. 44
3VolumeIn litres, centilitres or millilitres; on 75 cl, figures at least 4 mm high.1169/2011, Art. 9 · Royal Decree 1801/2008
4Provenance«Product of Spain», «wine of Spain» or «produced in Spain»: the country, not the region.119(1)(d) · 2019/33, Art. 45
5Bottler and packer numberName, municipality and country. In Spain, also the number in the Register of Packers (fictitious here).119(1)(e) · 2019/33, Art. 46 · Spanish Law 24/2003, 4th additional provision
6LotUsually preceded by an «L».Directive 2011/91/EU · Royal Decree 1808/1991
What stays printed even if you use the QR code
7Energy valueIt may use the symbol «E», per 100 ml.119(4)
8AllergensPreceded by «contains»: «Contiene sulfitos» on a Spanish label.119(5)(c)
9The legal QR code and what is insideNext to the code, the word «Ingredients» (and, if it holds the table, «nutrition information»). An «i» alone is not enough.119(4) and 119(5) · C/2023/1190, questions 2 and 38
Voluntary
AThe experience QR codeAllowed separately, as long as it does not confuse or take room from the mandatory items.C/2023/1190, question 31
BBarcodeRequired by retailers, not by wine labelling rules.

Everything goes in the same field of vision, so that it can be read at once without turning the bottle, in characters at least 1.2 mm high (Delegated Regulation (EU) 2019/33, Article 40). The lot, the allergens and the importer are the exceptions: they can go elsewhere. And in Spain, everything at least in Spanish (Royal Decree 1334/1999, Article 18).

What only some wines carry

Sparkling wines: the sugar content (brut nature, extra brut, brut, extra dry, dry, demi-sec or sweet) (119(1)(g) · 2019/33, Annex III). And for sparkling wines, the producer or seller instead of the bottler (2019/33, Art. 46).
Imported wines: the importer (119(1)(f)).
Wines without a designation of origin: the category, in the exact words of the regulation: «wine», «quality sparkling wine»… (119(1)(a)).
If your designation requires it: its own back label or seal, and the ageing terms set in its specification (Spanish Law 6/2015). It varies from one designation to another: check with its regulatory council.

Not mandatory

The best-before date: wine is exempt (Regulation (EU) No 1169/2011, Annex X).
The pregnancy pictogram, in Spain: no rule requires it. The 2025 bill on alcohol and minors is recorded by the Spanish Congress as lapsed, never passed (file 121/000050).
Ingredients and nutrition table on wines exported only outside the EU, since 18 March 2026 (Regulation (EU) 2026/471).

The rules for the legal QR code

The page that the legal QR code opens must follow these rules. The first two are in the regulation itself; the rest, in the Commission's official guidance.

No advertising.

Legal information cannot be shown together with commercial information (Art. 119(4) and 119(5)). No links to the winery's website or shop, no points of sale, no designs or sounds meant to attract the consumer. Linking to the winery's website is «undoubtedly» marketing (C/2023/1190, questions 36 and 37).

No tracking.

Data of the person who scans cannot be collected or tracked (Art. 119(4) and 119(5)). Not even with their consent (question 35).

Direct access.

The code leads to the information with no steps, forms or intermediate pages (question 35). And it must be a code a phone can read: printing a web address does not comply (question 33).

That wine's, not the winery's.

Each label leads to the information of that specific product (one or more lots of that wine), just like the paper label (question 34).

Stable while the wine exists.

The information must be legible, stable, reliable and accurate for the product's whole life. That is why the Commission has doubts about a page inside the winery's website, which can change at any time (question 30).

In the language of each country where it is sold.

The same language rules as the rest of the label (Art. 121 · question 38). That is why it pays off: the table and the list in several languages do not fit on paper.

What the law does not ask for, but helps you

Signing your label. The law does not require any electronic signature. It requires the information to be there, to be accurate and to carry no advertising. But if an inspection ever asks, you will want to show what you declared and when: a dated record of each version of your label is your proof.

A second QR code for everything else. The law allows other codes with voluntary information, as long as they do not confuse or take room from the mandatory items (C/2023/1190, question 31). That is where the wine's story, a winery visit or a purchase fit: everything the legal QR code cannot carry. It is QR code A on the back label.

And a single QR code for everything? The Commission says it «is not excluded», as long as the legal information is clearly separated from the rest (question 32). In practice it is risky: the legal page cannot carry anything commercial. The safest option is two codes, each with its own job.

What is coming

A common symbol. Regulation (EU) 2026/471 allows the Commission to set one pictogram for all of Europe to identify the e-label, instead of the word. As of 15 October 2026 it has not been published: the word «Ingredients» still applies.
More mandatory information through the same channel. The same regulation opens the door for the e-label to include other mandatory information in the future. The no-advertising and no-tracking rules do not change.
«Alcohol-free» and «alcohol-reduced». From 19 September 2027 they have their own terms (Regulation (EU) 2026/471).
The digital product passport does not reach wine. The EU regulation on digital passports excludes food (Regulation (EU) 2024/1781, Article 2).

Your legal QR code, free with SommelierLab

SommelierLab's legal QR code is free, with no limit on wines. It follows the rules above: no advertising, no tracking, no intermediate steps, one per wine and stable. It is published in all twenty-seven languages, and allergens and additives are copied from each language's official version, not translated. Each time you sign your label, what you declared and when is recorded. And if you ever stop being a customer, your legal label stays published.

Ingredients and nutrition are one part of your wine's identity. The legal QR code shows only that part, clean, as the law requires. What is wine digital identity →

Quick questions

Can I use only the QR code and remove the ingredients from the label?: Yes. The list of ingredients and the nutrition table can go only in the QR code. But the energy value, the allergens («Contains sulphites») and the word «Ingredients» next to the code stay on the paper.
So what do I gain by moving it to the QR code?: Room. The list of ingredients and the nutrition table, in every language where you sell, do not fit on a back label.
Can I link my shop or website from the ingredients QR code?: No. The Commission considers any link to the winery's website or shop to be marketing.
Can I know how many people scan the legal QR code?: No. Data of the person who scans cannot be collected, not even with their consent.
Is an «i» next to the code enough?: No. Today it has to say «Ingredients». Once the Commission publishes the common pictogram, the symbol will do.
Do I have to relabel the wines I already had?: No, if they were produced and labelled before 8 December 2023: they can be sold until stocks run out.
Is signing the e-label mandatory?: No. Signing it is your proof for an inspection, not a legal requirement.

This guide summarises EU and Spanish rules as of 15 October 2026. It does not replace advice from your adviser or what your designation of origin's specification requires.