Wine e-label: 2024 obligations and 2026 best practices

Since 8 December 2023, every bottle of wine and aromatised wine product produced in the European Union must display its list of ingredients and its nutritional values. This is Regulation (EU) 2021/2117, folded into the single CMO regulation 1308/2013, which brought wine into line with the general consumer-information obligations of the INCO regulation (EU 1169/2011). A welcome quirk: the information can be carried by a QR code — the now-famous “e-label” — provided the physical label retains a minimum baseline of information.

What must appear on the physical label

Article 119 of the CMO regulation, as amended by 2021/2117, clearly separates out what cannot be dematerialised:

• Energy expressed in kJ and kcal per 100 ml, on the physical label. It is the only nutritional value that cannot be pushed to a QR code.
• Allergens and substances causing intolerances (sulphites, egg, milk, etc.) must remain on the physical label, spelled out in full or via the standard pictograms.
• Traditional mentions: actual alcoholic strength by volume, nominal volume, sales designation, provenance, bottler, batch number.

What can be pushed to a QR code (the “e-label”)

The two pieces of information that can be dematerialised are:

• The list of ingredients in descending order of use: grapes, concentrated must, yeasts, additives, processing aids. Acids, stabilising agents (CMC, gum arabic), and antioxidants (SO₂) must be named.
• The full nutritional declaration: energy (repeated), fat, carbohydrates, sugars, protein, salt per 100 ml.

The QR code must be accompanied by a pictogram or a short mention (“i”, “ingrédients”, “ingredients”) unambiguously indicating the nature of the dematerialised information.

The eight rules for a compliant e-label

The guidelines published by the Commission on 23 November 2023 (notice C(2023) 8166 final) set out eight practical rules that every winemaker must follow:

1. No cookies, no trackers, no profiling. The e-label must function without collecting any user data beyond strictly anonymous technical telemetry.
2. No marketing. The target page must show no commercial information, no links to other products, no incentive to buy. The e-label of a Bordeaux cannot display, at the bottom of the page, “also discover our Sauternes”.
3. Permanence. The page must remain accessible for as long as the bottle can remain in circulation, in practice at least 10 years for ageing wines.
4. No excessive supplementary health information. Claims such as “zero sugar”, “rich in antioxidants”, “good for the heart” are banned under the INCO regulation as applied to wine.
5. Multilingual. The information must be available in every official language of the member states where the wine is marketed.
6. Readable without a download. The page must work on a standard smartphone without requiring the installation of an app.
7. The QR code itself must be non-commercial. The QR must lead directly to the information page, with no intermediate advertising page.
8. Batch traceability. The e-label can be unique to a single cuvée, but the operator must be able to document which batch it corresponds to.

Entry-into-force timeline

The regulation applies to wines produced from 8 December 2023 onward. In practice, this means:

• Wines from the 2023 vintage and earlier (harvested before 8 December 2023) are not affected. They can be sold until stocks run out under their original labelling.
• Wines from the 2024 vintage onward must carry a compliant e-label.
• For traditional-method sparkling wines, whose second fermentation often extends past December 2023, compliance is required from disgorgement onward.

Ingredients: the standard lists to know

The OIV (International Organisation of Vine and Wine) and the CEEV (European Committee of Wine Companies) have published standard ingredient lists by category. As a guide, a standard dry red wine will declare:

• Grapes (mandatory mention at the top of the list).
• Preservatives: sulphur dioxide (E220), sulphites.
• Where applicable: processing aids (casein, bentonite, gelatin, albumin, ovalbumin), which need not be mentioned if not present in the finished product in detectable quantity.

For organic wines (Regulation EU 2018/848), the list of authorised inputs is stricter: organic winemakers generally end up with shorter ingredient lists, which is becoming a commercial argument.

Common pitfalls

Three mistakes come up systematically in DGCCRF inspections and their European equivalents:

• Forgetting the “kJ / kcal” mention on the physical label. This is the most common failure and the easiest to sanction.
• Confusing the e-label QR code with a marketing QR code. A winemaker cannot have a single QR code that leads both to the ingredients and to a mini commercial site.
• Hosting the e-label page on an ephemeral domain. Using a URL shortener (bit.ly, t.co) creates a serious risk of broken links after 5 or 10 years.

Conclusion

The wine e-label is more than a regulatory constraint: it is an opportunity for winemakers to reopen a direct dialogue with their end consumer. Done well, it becomes a permanent, sober, neutral brand page that inspires trust — precisely the opposite of traditional advertising. Winemakers who invested early in compliant e-label platforms (including VeraTrace) report an unexpected side-effect: their wine merchants and restaurateurs use the page as a sales training aid too, which elevates the cuvée rather than commoditising it.