EU Digital Wine Label Compliance Is Essential but Premium Wineries Need More

Meeting EU digital wine label compliance is just the foundation—true innovation comes from Connected Labels that enhance traceability, transparency, and consumer engagement in ways that go beyond regulations.

Key Takeaways: What You Need to Know

  1. Guaranteed Compliance – Every Labellink-powered e-label includes a compliance certificate, providing verifiable proof of adherence to Regulation (EU) 2021/2117.
  2. Beyond Basic Compliance – If you are wondering how Labellink ensures compliance while making Connected Labels truly unique, read the full article to understand our approach.
  3. A Missed Opportunity Without Connected Labels – A basic digital label that merely satisfies legal requirements wastes the potential of a QR code scan. Connected Labels by Labellink transform that scan into a meaningful interaction with storytelling, AI-powered assistance, live engagement, and more.
  4. Two Compliance Areas to Navigate – Wineries must address both the transition from barcodes to GS1 QR codes (which enable traceability and structured data integration) and EU wine labeling regulations.

The world of wine is steeped in tradition, craftsmanship, and storytelling. With the implementation of Regulation (EU) 2021/2117, digital wine labels are now a legal requirement—but is mere compliance enough? At Labellink, we do not just meet regulatory standards; we elevate the entire wine experience. Because exceptional wines deserve exceptional digital labels.

Labellink: The Connected Label Difference

A Connected Label is more than just compliance—it is a comprehensive digital experience. It begins with a GS1 QR code, a globally recognized standard that enables full traceability, regulatory compliance, and operational efficiencies. When scanned, this QR code leads to a Connected Label User Interface, which presents the official EU-compliant label alongside Connected Label Tools designed to enhance consumer engagement, transparency, and convenience.

This approach integrates three key elements:

1. GS1 QR Code
Unlike an ordinary QR code, which simply directs users to a static website or landing page, a GS1 QR code is structured with standardized, machine-readable data that integrates with global supply chain systems. This means:

  • Built-in traceability – GS1 QR codes carry essential product data, such as batch numbers, expiration dates, and origin details, which can be scanned by retailers, regulators, and consumers for instant verification.
  • Regulatory compliance – Unlike ordinary QR codes, GS1 QR codes meet global standards, ensuring they align with regulatory frameworks and industry requirements.
  • Interoperability – GS1 QR codes can be used across multiple platforms, supply chains, and retail systems, making them an essential tool for wineries looking to scale operations and streamline logistics.
  • Stronger Retail Partnerships – Wineries using GS1 QR codes gain a competitive edge by meeting supply chain and regulatory standards favored by large retailers, supermarkets, and distributors, increasing their chances of becoming preferred suppliers in global markets.

 

2. Official EU Wine Label

  • A dedicated “Label” tab that contains only legally required information
  • Compliant with Regulation (EU) 2021/2117, ensuring transparency and trust
  • Strictly separated from marketing materials to avoid consumer confusion

 

3. Connected Label Tools

  • A purpose-built interface that enhances consumer engagement while maintaining compliance
  • Rich storytelling about the wine’s origin and winemaking process
  • AI-powered interactions offering smart recommendations and food pairings
  • Live customer engagement tools, such as direct chat support and guided tastings
  • Seamless access to certifications, sustainability details, and expert insights

 

By scanning a GS1 QR code, consumers first access the strictly regulated EU-compliant label. However, a true Connected Label offers a seamless experience beyond compliance—bridging traceability, legal compliance, and advanced digital engagement in one interface.

Understanding the Two Critical Compliance Areas: GS1 QR Codes and EU Wine Labeling

Wineries must consider two distinct compliance areas. First, the transition from barcodes to GS1 QR codes, which are fundamentally different from ordinary QR codes as they enable full traceability and structured data integration across supply chains. Second, compliance with EU wine labeling regulations, ensuring that legally required product information is properly structured, accessible, and clearly separated from marketing content.

Labellink is a key GS1 partner, providing a fully compliant solution that addresses both these critical compliance areas while offering extensive benefits beyond simple legal adherence.

Who is GS1?

GS1 is the global organization behind every barcode and GTIN, setting the standards that power global commerce. Today, GS1 is leading the transition from barcodes to GS1 QR codes, enabling businesses to provide connected, intelligent product experiences. This transition is transforming industries by improving traceability, efficiency, and consumer engagement.

Labellink ensures that wineries are at the forefront of this transformation by integrating GS1 Digital Link technology seamlessly into Connected Labels.

 

Compliance with Regulation (EU) 2021/2117 and Marketing Content Separation

Labellink ensures that all mandatory information—such as ingredients and nutritional values—is fully compliant with Regulation (EU) 2021/2117. This regulation mandates that mandatory product information must be clearly separated from marketing materials when provided electronically.

Direct Reference to EU Regulation:

Article 119 of Regulation (EU) No 1308/2013 (as amended by Regulation (EU) 2021/2117) states:

“The list of ingredients and nutrition declaration shall not be displayed with other information intended for sales or marketing purposes.”

The key term here is “displayed with”, which legally enforces a clear and functional separation between regulatory content and marketing materials.

 

Legal Definition of “Displayed With” and How Labellink is Compliant

The phrase “displayed with”, as stated in Article 119 of Regulation (EU) No 1308/2013, mandates the strict separation of mandatory product information from marketing-related content. In legal interpretation, “displayed with” pertains to both spatial proximity and functional presentation, meaning that two sets of information cannot be combined, embedded, or intermingled in a way that may cause confusion or mislead consumers.

Understanding “Displayed With” in EU Labeling Regulations

1. Spatial Distinction:
Mandatory information must be presented in a clearly defined, isolated section, ensuring it remains physically and visually separate from any marketing or promotional content. The structural organization of compliance-required data must be designed so that it is independent, easily accessible, and not intermingled with other types of information.

To meet compliance requirements, regulatory content must not be displayed within the same interactive or visual area as marketing materials. This prevents any possibility of consumer perception being influenced or regulatory content being misinterpreted as promotional messaging. Ensuring a clear functional separation between required product information and marketing elements guarantees compliance while maintaining a user-friendly and transparent presentation.

2. Functional Separation:
The user experience must be structured to ensure that a consumer first accesses the regulatory label before being presented with any marketing materials.
There must be no overlap between compliance-required elements and optional promotional tools in a way that blurs the regulatory purpose of the label.

3. Technical Enforcement:
Regulatory content must not be coded, stored, or retrieved alongside marketing data in a way that could present both at the same time within the same interface segment.
A clear back-end segregation must exist to prevent regulatory content from being dynamically altered or obscured by commercial information.

 

Why Labellink’s Solution Is Fully Compliant

Dedicated Compliance Section:
Labellink implements a “Label” tab that is structurally and technically isolated from marketing content. This ensures that no sales-driven information is intermingled with mandatory product disclosures.

User Flow Compliance:
When a consumer scans the GS1 QR code, the first page displayed is the official EU-compliant label. Only after reviewing the regulatory section can they navigate separately to additional Connected Label tools.

Technical Data Separation:
Regulatory label data is stored and retrieved from a secure compliance module, independent of any marketing-related content.
A clear UI/UX structure guarantees that mandatory disclosures are never modified, influenced, or obscured by commercial elements.

Regulatory Certification:
Every Labellink-powered e-label includes a compliance certificate, providing verifiable proof of adherence to Regulation (EU) 2021/2117.
The system is regularly audited to ensure continuous alignment with EU compliance standards.

By maintaining strict spatial, functional, and technical separation, Labellink ensures full legal compliance while enabling wineries to offer value-added digital experiences without violating regulatory mandates.
herence.

1

The Official Label tab is the actual legally required label, displaying only the mandated product information, strictly separated from marketing content to ensure full compliance with EU regulations.

2

Additional tabs provide Connected Label tools such as storytelling, AI assistance, live customer engagement, accessibility features, support tools, and e-commerce options—all clearly separated from the official label to ensure full compliance.

Click or tap on the red hotspot to view the explanation.

Labellink Compliance Tools That Simplify Compliance for Wineries

It’s important to understand that compliance is not just about using a compliant platform like Labellink. A winery can still enter incorrect or non-compliant information, leading to potential regulatory issues. However, Labellink prevents these mistakes and makes compliance easy, ensuring that wineries feel confident and secure with a set of powerful tools:

  • AI-powered content validation – Labellink’s AI scans wine descriptions and flags any non-compliant language, ensuring that only factual, regulation-approved information appears on the official label.
  • Pre-validated ingredient selection – Ingredients are selected from a pre-approved database using official names and standardized codes, eliminating errors and ensuring accuracy.
  • Automated compliance checks – Before publishing, Labellink performs multiple validation checks, verifying formatting, ingredient compliance, and GS1 QR code accuracy.
  • Accessibility and translations – Built-in tools ensure regulatory information is accessible to all users and seamlessly available in multiple languages.

With these powerful compliance tools, wineries can focus on delivering exceptional wines without worrying about regulatory missteps.

Compliance is Just the Beginning.
Do Not Waste a QR Code Scan!

Ensuring compliance with EU regulations and GS1 QR code standards is essential, but it should not be the final goal—it should be the foundation for something greater. A QR code on a bottle is more than just a regulatory requirement; it is an opportunity to engage, inform, and connect with consumers in a way that adds real value.

Consumers expect more than a static list of ingredients. They want transparency, traceability, and interactive experiences that help them make informed choices. A Connected Label turns compliance into a meaningful interaction, transforming every scan into a gateway for storytelling, AI-driven recommendations, live customer engagement, and multilingual accessibility.

Regulations define the minimum standard, but premium wineries should aim higher. A well-executed Connected Label ensures compliance is not just met but leveraged to create an experience that is engaging, informative, and beneficial to both consumers and brands.

Picture of Boris Motusic

Boris Motusic

Boris Motusic is the CEO of Labellink and United Experts, a seasoned Chief Solution Architect, consultant, author, and public speaker, with experience working on projects for global brands like Microsoft, BNP Paribas, ABB, Panasonic, and Best Western Hotels. LinkedIn Profile