QR codes for drinks labels, including the EU wine e-label
One code that rings up at the till and takes a drinker to your ingredients and nutrition, the vineyard or the brewhouse — built to the GS1 Digital Link standard, and editable after the label is printed.
In short
- Wine sold into the EU has had to carry an ingredients list and a nutrition declaration since 8 December 2023, and both may be given electronically — which is why a code on the back label is already normal for wine.
- The regulation attaches two conditions to that electronic label: no user data may be collected or tracked, and it must not be shown alongside sales or marketing content.
- Beer and spirits sit outside that particular rule, so for them the argument is the ordinary one — a crowded label, and a destination that can change after the print run.
- Great Britain has no equivalent requirement, so whether this is a legal question or purely a commercial one depends on where you sell.
Start free → or the Sunrise 2027 checklist →
Why a 2D barcode for beer, wine & spirits?
Drinks are the one category where an electronic label is already settled law rather than a forecast. Since 8 December 2023, wine and aromatised wine placed on the EU market must carry an ingredients list and a nutrition declaration — and the regulation expressly allows the full versions of both to sit behind electronic means identified on the pack, instead of on it. Producers selling into the EU have been doing this for years now. If you are exporting, you have probably already been asked for it.
For beer and spirits the case is different and simpler, because no equivalent rule applies to them. What applies instead is that a can or a bottle neck is a very small piece of paper carrying a lot of obligations, and craft producers change what is inside far more often than they change the artwork. A one-off collaboration brew, a single-cask bottling or a new vintage each get a page of their own without a new print run.
There is a constraint here we would rather name up front than have you discover later. The wine e-label provisions say in terms that no user data shall be collected or tracked, and that the declaration must not be displayed with information intended for sales or marketing. A scan that lands on your shop, or that feeds a dashboard, is not obviously what that had in mind. It does not make a Digital Link the wrong tool — it makes the destination a decision worth taking deliberately, which is why we will switch scan counting off for your account on request. The detail is below.
Underneath all of that the checkout is unaffected. A supermarket, off-licence or bar till reads the same GTIN it reads today, offline, and neither knows nor cares what else the code carries. Nothing about your listings, your wholesaler or your EPOS changes because the shape of the symbol did.
What to put behind the code
- The ingredients list and nutrition declaration — on a page of its own, if it is your e-label
- Vintage, vineyard, cask or batch detail for the bottle in hand
- Tasting notes, serving temperature and food pairings
- The brewery, winery or distillery's own story
- Responsible-drinking guidance and unit information
- Awards, competition results and where to buy again
What a page does that fine print can't
A web page can do things a printed beer, wine & spirits panel physically cannot: it can be read aloud by a screen reader, zoomed to any type size, searched for a single allergen, translated into the reader's language, and corrected after the pack has shipped. For a shopper with low vision, an allergy, or another language, that is the difference between information that exists and information they can actually use — and you don't have to build the page yourself: hosted pages serve it at the scan URL, cookie-free and changeable at any time after printing.
Where the rules sit for wine, beer and spirits
The live requirement is for wine. Regulation (EU) 2021/2117 amended Article 119 of Regulation (EU) No 1308/2013 to add an ingredients list and a nutrition declaration to the compulsory particulars for wine, applying from 8 December 2023, with an equivalent Article 6a inserted into Regulation (EU) No 251/2014 for aromatised wine products. Stock produced and labelled before that date may be sold until it runs out.
What may move to a scan is specific. Article 119(4) lets the nutrition declaration on the pack be reduced to the energy value alone — it may even be shown as the letter "E" — with the full declaration provided electronically. Article 119(5) lets the whole ingredients list be provided electronically. But allergens do not move: the substances listed in Annex II to Regulation (EU) No 1169/2011 must still appear directly on the pack, introduced by the word "contains". So the label keeps the energy value and the allergens, and the detail goes behind the code.
Two conditions come attached, and they are written into the operative text rather than left to guidance. The electronic declaration must not be displayed with other information intended for sales or marketing purposes, and no user data shall be collected or tracked. How far each reaches is genuinely unsettled — whether the marketing restriction covers only the same page or the whole site behind the code, and whether "collected or tracked" catches ordinary server logs as well as analytics, is not answered by the regulation itself. We are not going to answer it for you either.
Being concrete about our own product, since it is the honest thing to do: by default our resolver counts every scan. The counting is aggregate and privacy-preserving — no cookies, no stored IP addresses — but it is still telemetry, and we are not going to tell you it falls outside a rule that says no user data shall be collected or tracked, because the wording is unqualified and nobody can point to a settled answer yet. So if you are using a code as your mandated e-label, ask us and we will turn scan counting off for your account entirely. You lose the analytics; you gain a resolver that records nothing about the people who scan your bottles.
Finally, scope, because it is narrower than the words "drinks" suggest. None of this touches beer or spirits, which Article 119 does not cover. Geographically it is an EU requirement, and it applies in Northern Ireland; Great Britain never took it on, and in fact positively exempts drinks above 1.2% alcohol from the ingredients and nutrition rules altogether. A producer selling only within Great Britain is making a commercial decision here, not a compliance one.
Sources: Regulation (EU) 2021/2117 (adds the wine e-label) · Regulation (EU) No 1308/2013, Article 119 (consolidated) · Great Britain: assimilated Regulation 1169/2011, Article 16(4)
We build the barcode, not the compliance programme — this is background, not legal advice, and you should check your own obligations with someone qualified to give it.
Your beer, wine & spirits Sunrise 2027 checklist
Specific to beer, wine & spirits
Every brand does these
How you can check we're right
Every claim on this page is testable, and we'd rather you tested it than took our word for it.
- Paste a code into the parser to see exactly what a till reads out of it — the GTIN, the batch, the best-before, field by field.
- Read our GS1 conformance test results — the full suite we run against the standard, with what passes and what doesn't.
- Work through the Sunrise 2027 checklist for the general picture beyond beer, wine & spirits.
- Read what a Digital Link actually is — the structure, and why a till and a phone read the same symbol differently.
- Check the print size before artwork goes to press — the X-dimension GS1 specifies, and what it works out to in millimetres.
Common questions
Does the EU wine e-label have to be a QR code?
No. The regulation asks for the information to be provided by electronic means identified on the package, and does not name a technology. A QR code is simply what the trade settled on. The reason to make yours a GS1 Digital Link rather than an ordinary QR is that the same symbol then also carries your GTIN, so one code serves the e-label and the checkout instead of putting two on a back label that has no room for either.
Can my e-label page also market my wine?
This is the question to take advice on rather than take our word for. The regulation says the declaration must not be displayed with other information intended for sales or marketing purposes. Whether that restricts the page itself, everything reachable from it, or the whole domain is not settled by the text, and we would be inventing an answer if we gave you one. The cautious reading — a clean page carrying the declaration and little else — is the one most exporters have taken. If you want that clean page without building it, a hosted page on a custom template can be exactly that: served at the scan URL, no cookies, no scripts, showing the declaration and nothing else. Pair it with scan counting switched off — the next answer — before treating it as your e-label; the combination is our best reading of an unsettled text, not a compliance guarantee.
Can I still get scan analytics on a wine code?
You can, and you can also switch it off. By default we count scans in aggregate, with no cookies and no stored IP addresses, which for most products is simply good privacy practice. But the wine e-label provisions say no user data shall be collected or tracked, without qualification, and we are not going to claim our counting falls outside that when nobody can yet say authoritatively where the line sits. Ask us and we will disable scan counting for your account entirely, so the resolver records nothing at all. It is a request rather than a switch in the dashboard for now — email us and it is done.
Does any of this apply to beer or spirits?
Not the wine e-label rules — Article 119 covers wine and aromatised wine products, and beer and spirits are outside it. For them the reason to put a Digital Link on the pack is the practical one: the label is small, the information a drinker wants is not, and what you brew or bottle changes more often than what you print.
I only sell in the UK. Is there anything I have to do?
In Great Britain, no. The e-label requirement arrived in EU law after the UK's transition period and was never brought across, and assimilated law positively exempts drinks over 1.2% alcohol from the ingredients and nutrition duties. Northern Ireland is different, and so is any bottle you export into the EU. If you might sell into either, it is worth designing the label as though you will.
What still has to be printed on the bottle?
Everything Article 119 already required, plus two things the electronic route does not release you from: the energy value, which may be given as the letter "E" with a figure, and the allergen statement, which must appear on the pack as the word "contains" followed by the relevant substances. The full nutrition declaration and the full ingredients list are the parts that may sit behind the code.
Will a code on a bottle or can still scan at the till?
Yes. It is a GS1 Digital Link built around the GTIN you already hold, and a till reads that number offline exactly as it reads your current barcode. Worth testing on the actual container, though — a code wrapped around a slim can or a shouldered bottle neck sits on a curve, and curvature, not the standard, is what usually breaks a scan.
My labels change with every vintage or batch anyway. What do I gain?
Mostly that the page can outlive the print run and be corrected. A vintage sheet gets updated after the label is printed; a collaboration brew sells out and the code can point at what replaced it; a competition medal arrives a year after the bottling. Encoding the lot or batch number alongside the GTIN also lets a specific run carry its own page, which is what makes a targeted withdrawal possible rather than a blanket one.
Is it free?
Ten products are free forever — no card required. Pro is £10/month when you need more, with your own domain on the codes included.
Part of our wider guide to food & drink.
Also for supplements · cosmetics · household goods · agencies & printers.