Edit — an EU Wine E-Labels Include Marketing Content?

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A wine QR code can do much more than display ingredients and nutrition information.

It can introduce customers to a winery, share tasting notes, promote upcoming events, or provide a direct link to an online shop.

But if a winery uses a QR code to provide mandatory information under EU wine labeling rules, there are important restrictions on what can appear alongside that information.

**An EU compliance e-label cannot be combined with content intended for sales or marketing purposes.**

That does not mean wineries have to give up using QR codes for marketing. It means the compliance experience and the marketing experience need to be handled appropriately.

Here is what wineries should know.

## 1. What information belongs on an EU wine e-label?

EU wine labeling rules require applicable wines to provide a nutrition declaration and a list of ingredients.

Wineries can place the full information directly on the physical label or provide permitted information electronically.

When using an electronic label, the full nutrition declaration and ingredient list can be accessed through a QR code or another suitable electronic method.

Certain information must still appear on the physical label, including the energy value when the full nutrition declaration is provided electronically and the required allergen indications.

The purpose of the electronic compliance label is straightforward: to give consumers access to mandatory product information.

It is not intended to function as a promotional landing page.

## 2. Can an EU wine e-label include tasting notes?

Tasting notes are a natural part of how wineries communicate with customers.

Descriptions of aromas, flavor profiles, texture, and food pairings can help consumers understand a wine and decide whether to purchase it.

However, that is also why wineries should be careful about adding them to an electronic compliance label.

EU rules prohibit displaying the mandatory electronic nutrition declaration and ingredient list together with information intended for sales or marketing purposes.

Tasting notes used to describe or promote a wine are generally marketing-oriented content.

For example, a description such as "An elegant Pinot Noir with ripe cherry aromas, silky tannins, and a long finish" is designed to communicate the wine's qualities to potential customers.

**The safer approach is to keep promotional tasting notes on a separate winery or product marketing page rather than including them in the mandatory e-label.**

This allows wineries to provide a richer wine experience without mixing promotional material with the required information.

## 3. Can a compliance e-label link to an online shop?

No. A direct shop link should not be included alongside the mandatory electronic information.

The European Commission's guidance specifically identifies winery websites and e-commerce destinations as marketing-related.

A compliance e-label should not become a pathway that combines required ingredient and nutrition information with shopping links, purchase buttons, or promotional offers.

Examples of content to keep separate include:

- Links to an online wine shop
- "Buy now" buttons
- Product discounts and special offers
- Wine club signup promotions
- Promotional product recommendations
- Sales campaigns and limited-time offers

A winery can still make these experiences available through a separate marketing destination.

The important distinction is that consumers accessing mandatory information should not have to interact with marketing content to find it.

## 4. What about winery stories, photos, and social media links?

These are also better suited to a separate marketing experience.

A winery's history, vineyard photography, winemaking philosophy, and social media channels can all help build a relationship with consumers.

But when that content is used to promote the winery or its products, it falls outside the intended purpose of the mandatory electronic label.

For example, a digital page featuring a vineyard photo, the winery's history, an Instagram link, and a button to book a tasting may be useful for marketing.

It should not be used as the same page that provides mandatory electronic ingredient and nutrition information for EU compliance.

Keeping the experiences separate also makes each page easier to understand.

One answers questions about the wine's ingredients and nutritional values.

The other helps customers discover the winery.

## 5. Can a wine bottle have two QR codes?

Yes, provided the additional information complies with applicable labeling requirements and does not confuse or mislead consumers.

The European Commission's guidance recognizes the possibility of additional QR codes on wine labels.

For example, a winery could use:

**QR code 1: Ingredients and nutrition**

This code opens the mandatory electronic product information.

**QR code 2: Discover our winery**

This code opens a separate marketing page featuring the winery's story, wines, online shop, or tasting experiences.

The two codes serve different purposes.

When using multiple QR codes, wineries should make their destinations clear and ensure that the additional code does not obscure or detract from mandatory labeling information.

A simple description beside each code can help consumers understand which one to scan.

## 6. Why not use one QR code for everything?

Combining everything into one digital experience might initially seem more convenient.

A winery could imagine one page containing ingredients, nutrition information, tasting notes, product photography, and purchase links.

But when a QR code is being used to provide mandatory EU wine information, that approach creates a compliance problem.

The regulations require mandatory electronic nutrition and ingredient information to remain separate from sales and marketing content.

The European Commission also emphasizes that consumers should have easy and direct access to the required information.

Sending consumers to a general winery homepage, where they must search for the relevant wine and navigate through promotional content, is not an appropriate substitute for a dedicated compliance e-label.

A separate marketing QR code is a clearer solution for wineries that want both experiences.

## 7. How Winetraqr separates compliance and marketing

Winetraqr helps wineries create and manage digital wine labels containing product information such as ingredients and nutrition details.

Its compliance-focused pages are designed to present the required information without marketing or sales content.

For wineries that want to go beyond compliance, Winetraqr also offers Marketing Pages as a Premium feature.

These pages provide a separate, branded digital destination for the winery.

Wineries can use them to share:

- Their history and winemaking philosophy
- Vineyard and winery photography
- Information about their wines
- Links to their online shop
- Wine club signup destinations
- Tasting booking links
- Social media profiles

Marketing Pages are mobile optimized and can highlight the winery's active wines.

For EU wineries, Winetraqr recommends using a separate, secondary QR code for the marketing page rather than combining the experience with the mandatory compliance e-label.

This gives wineries a way to provide required product information while also creating a richer digital experience for interested customers.

## 8. Where should wineries use marketing QR codes?

A marketing QR code does not have to appear only on the wine bottle.

There are several opportunities to connect customers with a winery's marketing page.

### On a secondary bottle label QR code

A clearly identified marketing QR code can provide customers with a way to explore the winery after discovering a bottle.

### On tasting menus

Visitors can scan to learn more about the winery, explore its wines, or find its online shop.

### On tasting-room displays

A marketing QR code can help visitors access information about winery experiences, bookings, or wine club opportunities.

### On printed promotional materials

Brochures, event cards, and other winery materials can direct people to the same branded marketing destination.

### At wine fairs and events

A QR code can provide an easy way for visitors to find the winery online after meeting its team.

The purpose should always be clear.

Instead of placing an unexplained QR code on every surface, tell customers what they will find when they scan it.

## 9. What about QR code scan analytics?

Scan analytics are another area where compliance and marketing need to be distinguished.

EU rules prohibit collecting or tracking user data through the electronic information used to provide mandatory ingredient and nutrition declarations.

That restriction should not be confused with the broader use of QR codes for marketing.

Winetraqr Premium offers QR code scan analytics, including information about scan activity and geographic engagement.

For wineries using QR codes in marketing campaigns, this can help them understand which placements generate engagement.

However, analytics must be used in a way that respects the restrictions applicable to mandatory EU compliance e-labels and any relevant privacy requirements.

Wineries should not assume that tracking permitted for a marketing experience is also permitted for a compliance e-label.

## 10. How to plan your compliance and marketing QR codes

Before printing new wine labels or promotional materials, it helps to define what each QR code is supposed to accomplish.

Start with these questions:

1. **Is this QR code providing mandatory EU wine information?** If so, make sure it opens the appropriate compliance information without sales or marketing content.

2. **Do we want to share tasting notes or tell our winery story?** Use a separate marketing destination.

3. **Do we want customers to visit our shop or join our wine club?** Provide those links through a marketing page rather than the mandatory e-label.

4. **Will both QR codes appear on the bottle?** Make their purposes clear and check that the additional code does not interfere with mandatory labeling information.

5. **Have we tested the final experience?** Scan each code on the printed label and confirm that it opens the intended destination.

Thinking through these details before printing can help avoid confusion and unnecessary label changes later.

## Keep compliance clear and marketing useful

Wine QR codes can serve different purposes, but not every purpose belongs on the same page.

For EU compliance, the priority is giving consumers clear access to mandatory ingredient and nutrition information without mixing it with sales or marketing content.

For marketing, wineries have much more room to tell their story, showcase their wines, and connect customers with their shop, wine club, or tasting experiences.

Keeping these experiences separate helps each QR code do its job.

With Winetraqr, wineries can create and manage digital wine labels while using Premium Marketing Pages to build a separate branded destination for customers who want to explore more.

[Create your free Winetraqr account](https://winetraqr.com/) to start managing your digital wine labels and explore how Marketing Pages can support your winery.