Can you use the same QR Code and E-Label for multiple vintages?

We recommend creating a new QR Code and E-Label for each vintage, although it is technically possible to reuse a QR Code across vintages. Doing so involves important legal considerations and is not always compliant with EU regulations.

Below is an overview of recommended strategies, what is allowed, and what should be avoided when managing QR Codes and E-Labels.

There are four possible strategies to take around QR Codes and E-Labels for new vintages:

• New QR Code and E-Label per vintage, per product
• New QR Code per vintage, linking to the same E-Label
• Single QR Code and single E-Label, reused for multiple vintages
• One QR Code linking to multiple E-Labels (one per vintage)

New QR Code and E-Label per vintage

Recommended

This is our recommendation and what we consider to be the best practice. Creating a unique QR Code and E-Label for each vintage, size and wine allows you to:

1. avoid many of the potential legal issues you could have.
2. comply with GS1 Digital Link best practices.
3. easily create an E-Label from an older vintage in Bottlebooks.
4. easily manage your product data and QR Codes.

New QR Code per vintage, linking to the same E-Label

Available in Bottlebooks

Some producers are creating a new QR Code per vintage, but linking all of them to the same E-Label. This approach:

1. allows you to comply with GS1 Digital Link best practices.
2. requires you to adhere to all the Legal Key Factors listed below.
3. allows for flexibility, as you can easily redirect your QR Codes to a new E-Label if there ever is a legal requirement for a separate E-Label.

Single QR-Code and single E-Label, reused for multiple vintages

Available in Bottlebooks

This option is only acceptable if:

1. you fully and greatly understand and follow the legislation in all of the countries you will be selling in.
2. you are very careful about maintaining legal E-Labels, according to the Legal Key Factors listed below.

One QR-Code linking to multiple E-Labels (one per vintage)

Not Allowed

This practice is strictly forbidden.

1. Scanning a QR Code must immediately show a single, complete set of legal information.
2. Users should not see two sets of legal information.
3. User must not need to click to see information after scanning, such as choosing the vintage.

Key Legal Factors

Here are some of the key legal factors to consider when using the same QR code for multiple vintages:

1. The main principle is that, when the consumer scans the QR Code, they must see a legal ingredient and nutritional table. Vintage identification is not required. 
2. So far, only the German and Austrian regulators have confirmed this. Other EU regulators have not yet confirmed this and it may not be legal in those countries. 
3. Multi-information E-Labelling is not allowed. Consumers cannot see two or more ingredient lists and nutritional tables. They must not have to click or download to see the information. It is therefore forbidden to list several vintages with different information. 
4. The nutritional tolerances for energy and in the nutritional table are generous, but each vintage must be accurate. The tolerances can be found in this EU document on tolerances.
5. You cannot add or remove ingredients from vintage to vintage. There is an exception for stabilizers and acidity regulators, where you can add potential new ingredients in an "and/or" statement.
6. Updates to the E-Label made for newer vintages are not allowed, if they make the older vintages that are already using the QR Code non-compliant.  Adding (without the and/or statement) or removing ingredients, or changing the nutritional table (to values outside the tolerance for all vintages) will make older vintages non-compliant, even if they are not sold but only consumed.
7. If you are using GS1 Digital Link and you have a different GTIN per vintage, then you need to create a new e-label.
8. If you add additional information to the E-Label, please ensure it is not vintage dependent.

Updated on: 01/07/2025