The European Union has implemented stringent labeling regulations for wines, and complying with these regulations poses a challenge for wine manufacturers.
In recent years, the EU has made significant efforts to enhance the availability and accessibility of product sources and ingredient information for all food and beverage items. However, wines and aromatized wines have been exempted from comprehensive ingredient labeling requirements, being only obligated to disclose allergens and energy value due to the unique characteristics of the product. As the EU now mandates ingredient labeling for wines, wine manufacturers will encounter new complexities because a one-size-fits-all approach to ingredient labeling may not be suitable. This is because the composition of wines can potentially change during production, bottling, and storage processes.
No more special treatment for wines
Starting from December 8, 2023, wine brands within the European Union will no longer receive special treatment and will be obligated to adhere to the labeling regulations that apply to all other packaged foods and beverages.
This entails providing comprehensive ingredient and nutritional information on the product packaging. This poses a significant challenge for wine producers, not only due to the increased amount of information that needs to be displayed but also because wines, particularly vintage wines stored for extended periods, have a tendency to undergo changes in composition.
Currently, the majority of wine labels are printed by label printing companies prior to bottling. However, the composition of wine can undergo significant shifts not only during storage but also during bottling or blending processes. Furthermore, additional substances like sugar, acidifiers, or stabilizers may be introduced just before bottling, based on specific orders or product characteristics. This poses a challenge in accurately reflecting the correct composition on product labels, potentially impacting regulatory compliance and influencing consumer purchasing decisions and trust.
Static, pre-printed QR codes may not comply 
The use of static, pre-printed QR codes on labels has been suggested as a potential solution under the new Regulation (EU) 2021/2117, which requires wines and aromatized wines produced or sold in the EU to provide comprehensive ingredient and nutritional information. These QR codes would be connected to the brand and embedded on the bottle label, allowing access to detailed information. However, there are concerns regarding compliance with the regulation. Batch-level variations and potential changes in composition, even within the same tank or barrel, pose a risk of non-compliance if the QR codes are not updated with the latest ingredient composition at the time of labeling. Additionally, current QR codes often direct users to brand websites that primarily focus on marketing and sales. However, the new regulation specifies that electronic labels should not contain any sales or marketing information, although the finalization of this requirement is still pending.
Use inline-printed unique or batch-specific QR codes
One possible approach to comply with the new regulation is to utilize inline-printed QR codes that are unique to each bottle or specific to each batch with identical ingredient compositions. While it is still possible to generate unique QR codes externally by label suppliers, the most convenient method for ensuring compliant QR codes with accurate information is to print them directly on the production line. This allows for the use of a single label for the entire production lot, with a distinct QR code added at the final stage. This eliminates the need for managing smaller batches of labels for the same production run.
Implementing a QR code printing area on the label for each wine production line becomes necessary when utilizing product or batch-level serial printed QR codes. Although this space on the label will occupy a small area, it must maintain exceptionally high print quality. While external production of labels and QR codes remains an option, there is also an all-in-one solution available to achieve full compliance. This involves employing laser or thermal transfer overprinting (TTO) technology along with software capable of generating dynamic QR codes and cameras for verifying their legibility.
QR code caveat
The QR and other dynamic 2D codes are the solution to this requirement for full ingredient and nutritional information on the product post-production because the amount of information is considerable and could crowd and spoil brands’ label designs. However, under the new regulation, the following information must now be present on the label of the bottle itself or available via a dynamic 2D barcode or QR code:
– Category and source of wine
– Name of bottler, producer, and vendor, or importer in the case of wines produced outside of the EU
– Lot number and quantity of product
– List of intolerances and allergens
– Alcoholic strength (%)
– Sugar content (for sparkling wines only)
– Expiration date for de-alcoholized wines (10% alcohol content or less)
– Full ingredient list with nutritional and energy values per 100 milliliters
Importantly, the ingredient information which must be in an EU language and which we suggest could be accessed by a 2D code like a QR, must not be displayed alongside any form of sales or marketing material. This is a violation of the regulation which thus requires winemakers to set up separate microsites to provide this ingredient information. Using a link from an existing wine’s website risks falling foul of the law because of the associated tracking software used to track customer data which, by EU law, cannot be retrieved. Any failure to provide this detailed new information will incur fines and removal of the product from the market. Any wine already produced before 8 December this year is not subject to the new ingredient information demands, whenever it is sold the standard implementation rules related to the management of inventory on the market.
Connecting data to serial QR codes
Establishing a connection between data and serial QR codes is crucial for wine brands to ensure compliance with regulations and provide transparent information to consumers. Printing QR codes on labels is just one aspect of the solution. Wine brands will also need to link these QR codes to content from their enterprise data systems, allowing for accurate ingredient and manufacturing information on a per-batch basis. This linkage ensures regulatory compliance and enhances product transparency for consumers. Additionally, wine brands can utilize serial or batch-level QR codes to connect to non-ingredient-related product data, enabling improved supply chain tracking, visibility, and potential consumer engagement in the future, if permitted by regulations.
Combined print and software solution
To achieve this, it is essential to have appropriate software solutions capable of designing the digital consumer experience for ingredient labels and seamlessly connecting enterprise data systems to the packaging line and QR codes. Our partner Markem-Imaje offers an integrated solution by combining laser and thermal transfer overprinting (TTO) printers on production lines to generate high-quality labels and QR codes for various brands and products. Their Packaging Intelligence suite, powered by CoLOS® software, is specifically designed to work in conjunction with their printing technology. This software allows for the creation and management of unique or batch-specific QR codes, while the Blue Bite SaaS solution provides tools for brands to create and oversee digital experiences on mobile devices. These experiences can display digital ingredient lists and engage consumers with additional content.
CoLOS® software establishes a connection between the production line and a brand’s enterprise resource planning (ERP) system. It automatically retrieves relevant information, including serialization data and the most up-to-date ingredient composition, and makes it available through a dynamic QR code. This ensures the QR code contains accurate and accessible data. During the printing process, CoLOS® software utilizes powerful cameras for verification, ensuring the quality and legibility of the QR code.
A dynamic coding future
The introduction of this new EU regulation aligns with the transition towards the recently launched GS1 Digital Link, which is poised to become the global standard for product codification, ultimately replacing the traditional 1D barcode. By printing QR codes at the production line, companies can ensure compliance with the requirements of Digital Link, benefiting consumers, producers, and retailers alike.
Consumers can conveniently access a range of information, including both dedicated non-commercial data like ingredients and marketing details, using their smartphones. At the same time, retailers can utilize specific functionalities within the QR code for purposes such as charging customers and verifying product authenticity. Manufacturers can leverage the QR code for traceability, anti-counterfeit measures, and efficient recall handling processes. This dynamic coding future empowers various stakeholders in the supply chain ecosystem.
Article based on the content of our partner Markem-Imaje. Contact us at office@imarke.ro.
