PPWR for wine: what your labels need now, and how to do it in PinotQR

The short answer

Since 12 August 2026, every bottle of wine placed on the EU market must identify its packaging "manufacturer" by name and full postal address, either printed on the packaging or through a QR code. This comes from the EU Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40 (PPWR), which applies directly in all 27 member states and to wine from inside and outside the EU.

In practice, most wineries need to do three things:

1. Keep printing a lot or batch code on every bottle (you almost certainly do this already).
2. Add your full postal address and an email address to the new Packaging information section of your PinotQR e-label.
3. If you export to the EU, make sure your EU importer's name and full postal address are on the physical label.

Because PinotQR QR codes are dynamic, step 2 also reaches bottles you have already printed. You do not need to reprint labels to add the manufacturer details.

Who is the "packaging manufacturer" for your wine?

For a bottle of wine, the PPWR "manufacturer" is normally you: the winery that fills the bottle and sells it under its own name or brand. It is usually not the glass factory, the closure supplier or the label printer.

The word is misleading, so it is worth being precise. PPWR defines the manufacturer as whoever has the packaged product made under their own name or trademark. The European Commission's official guidance says that for sales packaging such as a filled wine bottle, the manufacturer is normally the filler, who is often also the brand owner. There is only ever one manufacturer per packaging.

The micro-enterprise exception is still unsettled for wine. The regulation moves the manufacturer role to the packaging supplier when the brand owner is an EU micro-enterprise and the supplier is in the same EU country. How this works when the bottle, closure and label come from different suppliers has not been clarified. The German Winegrowers' Association has asked the Commission and is awaiting an answer. If this applies to you, talk to your packaging suppliers and your trade association before deciding whose details to show. On our reading it does not apply to wineries outside the EU, because both businesses must be in the same EU country.

The two requirements on every bottle

Article 15 of the PPWR sets two separate requirements, and they are met in different places.

A full postal address means a real, deliverable one. Wine law only requires the town and country for the bottler. That is not enough for PPWR. Give the street and number (or PO box), postcode, town or city, and country. It must be one single point where you can be contacted.

For the electronic contact, use an email address, not your website. PPWR asks for an electronic contact if you have one. But EU wine e-label rules prohibit sales or marketing content alongside the ingredients and nutrition information, and the Commission has said a link to a winery website or webshop counts as marketing. An email address meets PPWR without creating a problem on the e-label.

The information must be clear and legible, and it must not be confused with other mandatory labelling. That is why PinotQR shows it in its own section, separate from your ingredients and nutrition declaration.

Exporting to the EU: your importer's details

If your wine is made outside the EU, you are still the manufacturer, and your EU importer has its own labelling duty under Article 18. The importer must add its name (or registered trade name or trademark), full postal address and, where available, an electronic contact.

The importer's details belong on the physical packaging. The regulation only allows a data carrier or accompanying document where putting them on the packaging is not possible. Wine law already makes "Imported by" a mandatory label particular, so the practical fix is to make sure that line, or the importer's back-label sticker, carries the full street address rather than just the town.

You can also show the importer in your PinotQR e-label. Treat that as a helpful extra, not a replacement for the printed details.

Expect your importer and EU retailers to check this. Importers must verify that you have met your manufacturer obligations before placing the wine on the market, and must keep a copy of your EU declaration of conformity. Distributors must check that the manufacturer and importer details are present before they sell the wine.

Selling direct to EU consumers with no EU importer involved raises separate registration duties in each country you ship to (extended producer responsibility). Those are outside the scope of this guide, but you still need the manufacturer details on every bottle.

How to set it up in PinotQR

Setup takes a few minutes per brand, and every wine in the brand picks it up automatically. Go to your brand's settings section and fill out the packaging manufacturer details for each of your brands. PinotQR gives you option to update all your previous e-labels at the same time to make life easy. Hit save changes and voila, your e-labels are now PPWR compliant.

Should you need to adjust these details on a per wine basis, you do this by editing the specific e-label and scrolling down to the Recycling section – you will find the details there to edit.

What still has to be printed on the bottle

The QR code covers the manufacturer details only. Three PPWR-related things still need to be physically on the bottle or its label:

• A lot or batch code. This is your Article 15(5) identifier. Make sure your bottling records show which bottle, closure, capsule and label were used for each lot.
• The importer's full postal address, for wine imported into the EU.
• The QR code itself, printed on the label or on a label that cannot be easily removed. A loose sticker is not acceptable under either the wine e-label rules or PPWR.

If you do not use a PinotQR e-label for a wine, print the manufacturer's name and full postal address on the label instead.

You do not need a second QR code for PPWR. EU rules discourage multiple labels and codes, and one PinotQR code can carry both your wine e-label and your packaging information, kept in clearly separate sections. You also do not need to print or publish your declaration of conformity; it is a document you keep for the authorities.

Bonus: your wine cases

Your 6- and 12-bottle cases are packaging in their own right, so they need the same two things as the bottle: an identification code and the manufacturer's name and full postal address. There is no general exemption for outer packaging.

The simplest approach is to print the same lot code as the bottles, your full address, and the importer line for EU shipments on the case's end panel. If space is tight, print the wine's PinotQR code instead of the address: it carries the manufacturer details.

Two things coming later are worth knowing when you next redesign cases. From 2030 at the earliest, grouped and transport packaging may contain no more than 50% empty space. Cardboard boxes are exempt from the 2030 re-use targets for transport packaging. Pallets and stretch wrap are outside the scope of this guide.

Stock you have already labelled

The rules apply to wine placed on the EU market from 12 August 2026. Wine placed on the market before that date can keep being sold as it is.

"Placed on the market" means the first time the wine is made available in the EU, not the bottling date or the date a shop sells it. For wine imported from outside the EU, it is the moment the shipment is released for free circulation at EU customs. So a pallet bottled in March but cleared through EU customs in September must comply.

For bottles produced before 12 August but placed on the market after it, the Commission says you do not need to destroy, re-make or re-label them. The required details can go in a document accompanying the shipment. If those bottles already carry a PinotQR code, the easier route is to add the Packaging information section to their e-label: it applies to every bottle with that code, including ones already in transit.

On enforcement, the Commission has told national authorities that non-compliant packaging should first lead to a request to fix it, not removal from shelves. Each country enforces this itself, though, and penalties can be significant: Germany's new packaging law allows fines of up to €200,000. Do not rely on leniency.

What is coming next

The next labelling change is a harmonised EU sorting label, due from 12 August 2028 at the earliest. It will be a pictogram showing the material of each packaging part (glass bottle, closure, capsule, case) so consumers know which bin it goes in. It must be printed on the packaging itself; a QR code cannot replace it.

The start date is 12 August 2028 or 24 months after the Commission publishes the design rules, whichever is later. The Commission missed its own August 2026 deadline for those rules, so the date may slip. Once it applies, national sorting labels such as those in France and Italy must go.

If you use refillable bottles in a re-use system, a "reusable" label plus a QR code with re-use information will be required from 12 February 2029 at the earliest.

We will update PinotQR and this article as the rules are published.

Checklist

• Confirm who the PPWR manufacturer is for each brand (you, a private-label customer, or possibly a supplier if you are an EU micro-enterprise)
• Add the manufacturer's full postal address and email in PinotQR and switch on Packaging information for each brand
• Check every bottle carries a lot code, and that your records link each lot to the bottle, closure, capsule and label used
• For EU exports, confirm your importer's full postal address is printed on the label or back-label sticker
• Add your full address (or the PinotQR code) and lot code to your cases
• Collect supplier information and keep an EU declaration of conformity and technical documentation for each packaging format, for at least 5 years

Sources

• Regulation (EU) 2025/40 (PPWR), EUR-Lex
• Commission guidance document for the PPWR, C/2026/3084, 10 June 2026
• Commission Q&A on EU wine labelling and e-labels, C/2023/1190
• Deutscher Weinbauverband: Verpackungs-VO – neue Pflichten
• Meininger's: Wine producers face unpopular packaging regulations in the EU
• Tanso: summary of the Commission's second PPWR FAQ, 31 July 2026

This article is general guidance based on the regulation and official Commission guidance as of the date above. It is not legal advice. Commission guidance is not legally binding, and some points (notably the micro-enterprise rule) are still being clarified. Check with your trade association or a regulatory adviser for your specific situation.