Articles on: E-Labels

How to Print the Back Label with an EU QR code

To meet EU E-Label requirements, your back label must include a few essential elements.

The content in this article is not legal advice. Please consult a lawyer or regulator for clarity.

Required Elements

Energy Declaration

Include the energy value per 100 ml, expressed in kJ and kcal. This formula can be used 100mL: E=XXXkJ/XXXkcal.

Do not capitalize ml (or mL), as this would stand for megalitre.

Text Next to the QR Code

There must be text next to the QR Code, clearly indicating what the QR code is for.

This text must contain the word “ingredients”. Suggestions are:

“Ingredients”
“Ingredients and Nutritional Values”
“Ingredients / Nutritional Values”

EU Member States are not fully aligned on the wording for the call-to-action. Some accept ‘Ingredients’ alone, while others require ‘Ingredients and Nutrition’. Non-legally binding EU guidance states that the word "ingredients" is sufficient. Since there is no unanimous interpretation, this remains under discussion at EU level.

Language

“Ingredients” can be written in any EU language, however, it would be best to write it in the language that the label is in.

The European Commission has confirmed that the call-to-action, like other labelling elements, must follow Article 121(1) of the CMO Regulation, meaning it may appear in any one official EU language, even if that is not the official language of the country where the product is sold.

The QR Code

Minimum size: 11.49 mm x 11.49 mm.
Include a quiet zone to bring the total size to 14.66 mm x 14.66 mm.
Use high contrast, preferably black on white.
Avoid symbols, such as “i”, which reduce scanability.
Test the QR Code on multiple devices.

GTIN

If you wish to comply with GS1 Digital Link, then you need to include the GTIN next to the QR code.

This information can be added to the back label or on a separate sticker that is commonly used for smaller batches of imported wines. There are some basic principles that must be adhered to:

All this new information needs to be grouped together in the same field of vision as the other compliant information such as alcohol % and volume.
The sticker must stay on the bottle until it is consumed.

Printing the QR Code

It is critical to ensure that your QR Code is printed properly. For more details on this, please refer to How to Design and Print QR Codes.

Updated on: 24/07/2025

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