Design guidelines for the EU labelling regulations

In this article we discuss the required information on both the physical label and digital e-label, then provide a breakdown for label designers to ensure they're meeting the regulation - with examples.

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As of the 8th of December 2023 there are new laws in place for all wine sold in Europe. These laws not only apply to countries exporting their wine into Europe, but also European producers themselves – so, we're all in the same boat.

In essence, the law is aimed at exposing the ingredients that make a wine, including it's energy and nutritional breakdown. The wine drinker must be able to access:

• a nutrition declaration
• an energy value, and;
• a list of ingredients.

And to top it off, all of this must be available in the native language of the country you're selling to, of which there are 24 languages.

QR Codes vs Physical Wine Labels

There are two ways of achieving this:

1. Print all this information on a physical label on the back, and have a physical label in each language of the country you want to sell into, or;
2. Add a QR code to the back wine label and display that information digitally.

We highly recommend the latter, purely because it future-proofs winemakers against future law changes (digital can be adjusted, print can not). We can also automatically translate this information into the 24 European languages which means you're compliant anywhere you end up selling your wine. *

* You would have to print a different back label for each country/language.

Required information

So, what is actually required on both the physical bottle label and the digital e-label if you're going to use a digital e-label service like PinotQR?

There's already been a fair few changes since the new regulation has announced but one key thing to remember is that this regulation is about exposing nutritional information and not for marketing. Any attempt to market or advertise your brand within the QR code experience is actually a violation of the law, of which a number of our competitors are currently in breach of - and hence why we've been combing the regulation each time it changes to make sure we absolutely reflect the requirements in our e-labels.

This article is for designers, and therefore should focus specifically on the physical label design, however we think it's important to understand what the e-label handles to understand what the role of the QR code is.

On the physical wine label

The beauty of the QR code approach means the e-label has handled the bulk of the information needing to be displayed to your customers to meet the regulation. However, you still need to get a few things 'right' on the bottle label.

On your wine label you need to display:

1. Energy amount per 100ml in Kcal and KJ
2. Any allergens
3. A QR code accompanied by the word "Ingredients"

Plus, if you are selling in Italy you must print the recycling declaration on your bottle - it can't just be on your digital e-label.

On the e-label (QR Code)

The e-label just means 'electronic label' and is essentially a web page that displays the required information to meet the new regulations. What appears when you scan a PinotQR QR code is:

1. A list of the ingredients found in the wine, broken down by category
2. A nutritional information table displaying data like energy, fat (of which saturates), carbohydrates (of which sugars), protein and salt
3. Allergens - this is an optional extra for user experience that we've added to the e-label but do note this must be on your physical label

What we also include, but it's required by law is the name of the wine, photo, vintage and variety for identification purposes.

What the e-label shouldn't do (non-exhaustive list):

• It can't have any branding, other than an image of the specific wine bottle
• There can't be advertising on the web pages
• You can't link from this page to your website.

These may change with time, but it's important to remember this whole experience is solely to meet regulation and the more information added beyond the required data could lead to being non-compliant. Our competitors have got this wrong and caused costly issued for their customers so be careful who you choose.

The QR Code guidelines

Dimensions

The regulations don't specify a size, however it must be marked conspicuously and easily visible/legible. We recommend testing your QR codes as printed to make sure they are easy to scan.

The QR code must be clearly distinguishable from surrounding text/graphics. Anywhere between 13mm and 16mm in size will scan well. We also recommend printing 300 dpi or higher to prevent issues with scanning. QR codes will also have a quiet zone of clear space around the QR code. You should discuss the size with your specific printing provider.

If you attach any language to your QR code on the physical label (eg a call to action like “scan here for nutritional information”), our understanding is that it may trigger the obligations to provide that language in every language that consumers may encounter it.

Positioning

The QR code, the energy amount and allergens must be in the same 'field of vision' when a customer is looking at your bottle.

This data can either be part of your label design, or a separate sticker itself as long as it meets the field of vision rule and can not be easily removed.

Font & spacing

The usual legibility rules apply for the supporting energy and allergen information – make sure the text is at least 1.2mm tall based on the height of a lower case 'x' character.

Colour

You are free to use any colour that you prefer to style the QR code to match your label. However, you should ensure that there is enough contrast between the colour of your QR code and the background. As a general guideline, always use light-coloured backgrounds and dark-coloured foregrounds, not the other way around.

We recommend doing a test print and seeing how easy it is to scan with a few different devices.

Energy value

The energy values must be per 100ml, displayed near the QR code and in kilocalories and kilojoules.

In summary

Well, to keep things simple - make sure you've got one of our QR codes printed on your label with the "Information" text underneath it. Includes your energy, allergens and Italian recycling declaration values and let the digital e-label handle everything else.

Good luck and if you have any further questions please contact our support team on team@pinotqr.com.