E-labels Master Guide
- David Lees
- Jun 13, 2023
- 9 min read
Updated: Oct 4, 2024
See example E-label here: E-label example Learn how to fulfill the European regulations on wine ingredients and nutritional labeling.
“In order to provide a higher level of information to consumers, the compulsory particulars…. should include a nutrition declaration and a list of ingredients. However, producers should have the option of limiting the contents of the nutrition declaration on the package or on a label attached thereto to only the energy value and of making the full nutrition declaration and the list of ingredients available by electronic means, provided that they avoid any collection or tracking of user data and do not provide information aimed at marketing purposes.”
Contents
Overview
Providers
Creating E-labels
Printing
References
Disclaimer
This is our best interpretation of the laws and compilation of respected legal opinions in the European Union around the nutritional and ingredient declaration for wine. Please consult legal advice from a professional for the most up-to-date information. This information is also subject to change.
Requirements for E-labels
For any wine sold in the EU, you must provide:
List of ingredients
Nutrition information
Attention: If wines can be directly ordered by the end consumer on a price list, brochure, flyer, online shop, etc. (e.g., by phone, in writing, by fax), the ingredient list and nutrition information must also be provided at purchase.
8th of December 2023
The regulation applies to wines produced on and after the 8th of December 2023 for sale in the EU.
2024 vintage
All wines with the 2024 vintage and beyond need to comply.
2023 vintage
To be considered “produced” the wine must reach the properties required for the product in accordance with the EU market regulations. This includes alcohol, acidity, and in the case of sparkling, pressure. For sparkling wine that is produced through a second fermentation, this fermentation must be completed.
Producers have started to comply. Bottlebooks is offering forever discount codes so that any additional cost to start early will be recovered over time.
Be aware that retailers, importers, and customs officials are likely to be gatekeepers requiring compliance earlier, so it is important to talk to your distribution partners.
For imported products, VI-1 document and VI-2 extracts will require the list of ingredients. You can export the VI-1 data directly from Bottlebooks.
For bulk wine, the list of ingredients must be included in the accompanying documentation through the lifecycle from the producer, bottlers, processors, and finally to the merchants.
Spirits are expected to follow soon.
Using E-labels (QR codes)
The full nutritional table list of ingredients can be available through an e-label - a QR code on the printed label that links to a mobile webpage.
There are a number of conditions that the e-labels must meet whether you use your website or a third-party supplier such as Bottlebooks.
Translated. The labels need to be translated into the languages of any country you might sell in using the official EU translations.
Lasting. Your e-labels must last as long as the wine is expected to remain fit for consumption under normal storage.
No user data may be collected. That means no tools such as Google Analytics. (Only location is allowed to be collected in order to deliver the appropriate language.)
No sales. No marketing or selling your wines is allowed.
No downloads. There should be no PDF or other downloads.
No navigation. The user should not have to click to get to another page with the information. Note: there is one source of legal advice that is suggesting navigation might be allowed. We will clarify if we know more.
What if I just put the information on my website?
You are allowed to, however you must just meet all the conditions above. For most producers, this will be unrealistic and more costly than using a third-party solution as it will require setting up a separate website infrastructure from your marketing website and online store.
Bottlebooks E-labels
We built Bottlebooks E-labels with consultation of compliance teams and managers from producers large and small. We aimed to make the most producer-friendly, easy-to-use, legally compliant system.
Bottlebooks E-Labels:
Complies with the EU legislation
Reviewed by EU lawyers and regulators
Uses official EU translations to automatically translate to all EU languages
Lets you use your Bottlebooks data
Includes Italian recycling package requirements
Does not charge for older labels that would raise your subscription price over time
Allows you to switch away from Bottlebooks to your website or another provider at anytime
Bottlebooks is the largest wine product data network in the world. Our clients include the largest 20 producers, ProWein, California, Spain, Waitrose, and Ahold Group.
You can create 3 free e-labels today (no commitment or credit card required) on Bottlebooks
Other E-labels Providers
This guide will refer to and use Bottlebooks E-labels to help you get compliant, however there are a number of other e-label providers.
We have not verified these services. Some of that we have tested clearly will not comply with the legislation, so please do your own research.
The following is a list of a few of the providers we have heard of:
Members of the SAFE E-label group with Bottlebooks: https://safe-elabel.org/
Advanced Track and Trace Track and trace technology leaders
Dans ma Bouteille Dedicated to ingredient transparency with wine
Vin.co Sales and marketing solutions for wineries
Other providers
Digilabel A South African industry solution
Flabel A collaboration of Artify and Euvinopro
Scantrust Track and trace platform
Ulabel A recently founded e-labels only company
Imero A QR code company
Get Started on E-labels
Follow the link below to create 3 free e-labels today on Bottlebooks (no commitment or credit card required).
After you sign in or sign up follow the instructions to create your first E-label. You can find more in our guide: https://bottlebooks.freshdesk.com/support/solutions/articles/19000139111-how-to-create-e-labels-guide
Through this process you will be guided to create a compliant e-label. There are five main components of the e-label that you will complete:
Product identification
Ingredients list
Nutritional values
Packaging
Optional information
Product identification
It is recommended that you create a new e-label for every:
new product
new size
new vintage
In the future, the QR code is slated to replace the barcode to be scanned at checkout. This is supported in Bottlebooks as GS1 digital link.
Caution: once an e-label is in the market, you should not update it unless the information needs to be corrected. For instance, do not use the same e-label for the new vintage by updating the information on the old vintage e-label. This will result in non-compliance with the old vintage.
Ingredients
Bottlebooks uses the official EU ingredients in our ingredients picker. Our system will format your list to meet the legislation. For example, Bottlebooks will bold allergens to differentiate them from the other text.
When picking the ingredients, there are a few rules you need to be aware of.
You are able to use either the proper ingredient name or the corresponding E number.
For “grape must” you should use “grapes”.
For “rectified concentrated grape must” you should use “concentrated grape must”.
The terms "tirage liqueur" and "shipping liqueur" may also be indicated without further specification of the individual ingredients.
You are allowed to add three ‘acidity regulators’ and ‘stabilising agents’ as long as one is used in the process. Bottlebooks will group them in a “contains and/or” as statement according to the regulation.
If multiple wines are blended, it is recommended to list all used ingredients in total (e.g., mention sugar, tartaric acid, or sulfur dioxide only once in the list).
Ingredients must be listed in descending order of weight as they were used during the manufacturing of the food. Ingredients that make up less than 2% of the finished product may be listed in any order, after the other ingredients. Refer to ANNEX VII of EU 169/2011. Click on the six dots next to any ingredient and drag and drop to reorder.
Certain additives used as packaging gasses (carbon dioxide, argon and nitrogen) have as a main objective the displacing of oxygen during the bottling of grapevine products,
but they do not become part of the product that is consumed. In these cases you can choose to add “Bottled in a protective atmosphere” or “Bottling may happen in a protective atmosphere”.
Nutritional Label
You may use the Bottlebooks calculator or manually enter your own data.
Bottlebooks use the following formula to calculate energy.
kcal per liter = ((7.9 x alcohol) x 7) + (residual sugar x 4) + (total acidity x 3) + (glycerin x 2.4)
For wines with a sugar content below 100 g/l (typically all wines except sweet wines), a tolerance of 2 g/100 ml (equivalent to 20 g/l) is allowed for the declaration of sugar/carbohydrates.
Fat, saturated fat, protein and salt are only contained in wine in negligibly small quantities for if good production practices are adhered to for almost all wines. You have three options in Bottlebooks for negligible amounts of fat, saturates, protein and salt. You can enter "0" as a value, you can choose one of the "< " statements, or you can select the "< " statements and then tick the box next to "Show simplified table for negligible amounts (Fat, Protein, Salt)".
More information on negligible amounts can be found in section 6, table 4 of the EU guidance documents on nutritional labeling for EU 1169/2011 among others. You are responsible for declaring values that exceed these tolerances, however many associations and legal experts are declaring that for typical wines no additional test is necessary.
Packaging
It is required in Italy to indicate the material identification code on your packaging and provide the waste collection guideline according to Decreto legislativo 3 aprile 2006, n. 152.
This can be entirely done through the Bottlebooks e-label by searching for and selecting the materials you are using.
Imprint/Impressum
The Impressum (or Imprint) is a required page on all websites in Germany, Austria, and Switzerland that states information about the publisher of that site. An Impressum is a basic legal notice that tells website visitors about the website or business owner.
An Impressum usually includes the following:
Name of the owner or manager of the website
Registered business address
Contact information (i.e., phone number, email address)
Official incorporation information (i.e., official name and registration number of the company)
Optional Information
There is a variety of optional information you are permitted to add to your e-label.
This includes:
Certifications (note: some experts feel organic certificate will not be allowed)
Your logo
Varietals
Alcohol
Responsible consumption
Food business operators
In any of these cases, if you put the information on the e-label, it does not exempt you from also putting it on the label when required.
Printing the Back label
You need to add three elements to your back label:
The energy in kj and kcal. This formula can be used 100mL: E=XXXkJ/XXXkcal. Note: Do not capitalise ml (or mL) as this would mean megalitre. ML (or Ml) stands for megalitre.
There must be text next to the QR code clearly indicating what the QR code is for. This text must contain the word “Ingredients”. Suggestions are “ingredients”,or “ingredients and nutritional values” or “ingredients / nutritional values”. “Ingredients” can be written in any EU language, however if the label is in say German, it would be best to write it in German.
The QR code.
Size. According to international standards (ISO/IEC 15415) the QR code should be at least 11.49mm x 11.49mm. Then there should be a quiet margin to bring the total size to 14.66 x 14.66 mm.
It should be of high contrast, ideally black on white
Symbols can be used but reduce the readability and so are best avoided.
Test the QR Codes often with multiple devices
If you wish to comply with GS1 Digital Link then you need to write the GTIN next to the QR code.
This information can be added to the back label or on a separate sticker that is commonly used for smaller batches of imported wines. There are some basic principles that must be adhered to:
All this new information needs to be grouped together in the same field of vision as the other compliant information such as alcohol % and volume.
The sticker must stay on the bottle until it is consumed.
It is critical you ensure your QR code is printed properly. We have created a separate guide for you:
Note: For all grapevine products that have undergone a de-alcoholisation treatment and have an actual alcoholic strength by volume of less than 10% it is appropriate to establish the date of minimum durability on the label.
Note: You can have two QR codes, another for marketing, but there must be no confusion as which one is which.
Printed label with no QR
For printed labels with no QR code, you can use Bottlebooks to create your own ingredient and nutritional values.
Simply follow the steps above to complete the information in Bottlebooks. You can then copy and paste the ingredients list and, after publishing, you can go to the downloads tab in the product to copy out the nutritional table.
Note: some legal guides state that you can use the statement “contains negligible amounts of fat, saturated fat, carbohydrates, protein and salt” to replace stating those values in the table.
Links
Learn more: https://www.bottlebooks.me/e-labels
Get started: http://elabels.bottlebooks.me/
Simple Guide and Infographic: https://www.bottlebooks.me/post/a-simple-e-label-guide
The Main EU Regulations
Outlines the use of electronic labels to deliver nutritional and ingredient information.
Penalties include removal from the market and fines. See Chapter IV, Article 89 and 90a in Regulation (EU) 1306/2013.
The EU provided some non-legally binding answers to key questions.
Ingredients names and terms
Supplemental regulation on aromatised wines
Italian recycling regulations
Set the tolerances for nutritional values
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