Introduction
A single small mistake on the label can cost you thousands of euros.
EU Regulation 2021/2117 on wine labeling has strict requirements, and food surveillance authorities are increasingly checking compliance. We see the same mistakes over and over â mistakes that lead to sales stops, fines, and costly corrections.
In this article, weâll show you the 7 most common mistakes and how to avoid them from the start.
Mistake #1: Energy Value Missing from Physical Label
The Problem: Many winemakers think they can simply print a QR code on the label and put all information in the e-label. This is a fatal error.
The Regulation: The energy value (in kJ and kcal per 100ml) must appear on the physical label. A mere reference to the QR code is not sufficient.
The Consequence: Wines without energy value on the label may not be sold. Authorities can order an immediate sales stop for the entire batch. This means: relabeling all affected bottles or â in the worst case â destruction of the goods.
The Solution: Integrate the energy value directly into your label design. The compact statement âE= 350kJ (84kcal)/100mlâ takes up little space and protects you from expensive consequences.
Mistake #2: Allergens Only in QR Code
The Problem: Allergen warnings â particularly âContains Sulfitesâ â are often placed only in the e-label, not on the physical label.
The Regulation: Allergens must be readable directly on the bottle, not just accessible via QR code. This serves the immediate protection of allergy sufferers who need to quickly identify in the store whether a product is suitable for them.
The Consequence: Beyond the sales stop, there are special civil law risks here: if a consumer has an allergic reaction because the warning wasnât directly visible, compensation claims may follow.
The Solution: The allergen warning âContains Sulfitesâ (and any other relevant allergens such as egg or milk components) must be clearly visible on the label â not hidden in small print but clearly recognizable.
Mistake #3: Marketing Content Mixed into E-Label
The Problem: The e-label is used as a marketing channel: product descriptions, awards, shop links, or social media links are displayed together with mandatory information.
The Regulation: The EU regulation is clear here: the e-label may only contain the prescribed mandatory information:
- Nutritional information
- Ingredient list
- Allergens
Not permitted:
- Tasting notes and product descriptions
- Awards and medals
- Buy buttons or shop links
- Newsletter sign-ups
- Social media links
The Consequence: Marketing in the e-label constitutes a legal violation and can be penalized with fines.
The Solution: Keep your e-label strictly factual. If you want to offer additional information, use a separate QR code for marketing purposes â but not the same one as for mandatory information.
Mistake #4: Data Collection via QR Code
The Problem: Some e-label solutions use cookies, tracking pixels, or analytics tools to collect user data. Google Analytics, Facebook Pixel, or similar services are integrated.
The Regulation: The EU regulation explicitly prohibits any form of data collection via the e-label:
- No cookies
- No tracking pixels
- No analytics tools
- No storage of IP addresses
- No device recognition
The Consequence: Violations of these data protection requirements can be penalized not only under food law but additionally under GDPR â with correspondingly higher fines.
The Solution: Choose an e-label provider that works 100% tracking-free. With nutri.codes, no user data is collected whatsoever â no cookies, no analytics tools, no IP storage.
Mistake #5: Missing or Incorrect Translations
The Problem: The e-label is only available in German, even though the wine is also sold abroad. Or the translations were created with Google Translate and contain technical errors.
The Regulation: Mandatory information must be available in the official language of the sales country. If you export to France, you need a French version. To Italy â Italian. English as an âinternational languageâ is not an acceptable alternative.
The Consequence: Wines with missing translations may not be sold in the respective target country. In the worst case, batches already delivered are removed from the market.
The Solution: Use an e-label system with professional, wine-specific translations in all relevant EU languages. Automatic language detection ensures consumers see the information in their language.
Mistake #6: Font Too Small or Insufficient Contrast
The Problem: The mandatory information is present but printed in such small font that itâs practically unreadable. Or the contrast between text and background is too low.
The Regulation: The EU regulation specifies a minimum font size: the x-height (height of the lowercase letter âxâ) must be at least 1.2mm. Additionally, sufficient contrast between text and background must be ensured.
The Consequence: Unreadable information is considered non-existent â with the same consequences as missing information: sales stop and possible fines.
The Solution: Check before printing that all mandatory information meets the minimum size. Avoid light text on light background or vice versa. When in doubt: print a bit larger.
Mistake #7: Retention Period Not Considered
The Problem: The chosen e-label provider doesnât guarantee long-term availability. After a year, the service is discontinued or prices increase drastically.
The Regulation: E-label information must be available for at least as long as the wine is on the market â plus an appropriate period for consumption. In practice, this means: at least 10 years of availability.
The Consequence: If your QR code suddenly leads nowhere, all bottles already in the market are no longer compliant. You are liable for the availability of the information.
The Solution: When choosing your e-label provider, look for a contractually guaranteed retention period. nutri.codes guarantees availability for at least 10 years â documented in writing in our terms and conditions.
Bonus Tip: Not Starting Early Enough
The biggest mistake is putting off the topic. The later you deal with the new labeling, the more stressful the implementation becomes.
Our recommendation: Start now with a test wine. Go through the complete process once before converting your entire product range. This way you identify potential problems early and have enough time for corrections.
Checklist: Avoid These Mistakes
Use this checklist for your wine labels:
- Energy value (kJ and kcal) present on physical label
- Allergen warning (âContains Sulfitesâ) on physical label
- E-label contains NO marketing content
- E-label uses NO cookies or tracking
- Correct translations for all export markets
- Font size at least 1.2mm x-height
- Sufficient contrast for all information
- E-label provider guarantees retention period (min. 10 years)
If you can check all items, youâre on the safe side.
Want to play it safe? Try nutri.codes for free and create EU-compliant e-labels without risk.