One QR Code, Multiple Vintages: What Wine Producers Need to Know
Can wineries use the same QR code and e-Label for multiple vintages? The answer can depend on many factors. While reusing a QR code across vintages might seem like an easy solution, EU regulations enforce strict standards to ensure accuracy and transparency. In this article, we’ll explore when reusing a QR code is possible, what the risks are, and why using a new QR code for each vintage might save you trouble in the long run.
When the QR Code is Scanned
When the QR code is scanned, the user needs to see the ingredient list and nutritional details that comply with EU requirements. The information must match the specific wine the customer is buying. While German and Austrian authorities have confirmed that including the vintage isn’t necessary, other EU countries haven’t provided clear guidance yet. This creates a risk of non-compliance or the need for adjustments across different distributors in the EU.
For an e-Label to Comply with EU Regulations
For an e-Label to comply with EU regulations, it must provide clear and direct information. A single e-Label cannot display multiple ingredient lists or nutritional tables for different vintages. Customers should not need to click through or download anything extra to find the details specific to the wine they’re purchasing.
Nutritional Flexibility
While the EU allows for some flexibility in energy and nutritional values, the details must still be accurate for each vintage.
Consistency in Ingredients
When it comes to ingredients, they must remain consistent across vintages, meaning you cannot add or remove ingredients from one vintage to the next. The only exception is stabilizers and acidity regulators, where you’re allowed to use an "and/or" statement to account for potential variations.
Updating an e-Label for a New Vintage
When updating an e-Label for a new vintage, you must ensure that the changes do not render previous vintages non-compliant. Adding or removing ingredients, or altering nutritional values beyond the allowed tolerances, can create compliance issues for older vintages—even if they’re no longer sold but are still being consumed.
Conclusion: Is Reusing a QR Code Worth It?
To sum up, using the same QR code across vintages is possible, but it comes with risks. The information linked to the QR code must always stay accurate and compliant for every vintage. For simplicity and peace of mind, it’s often better to create a new QR code and e-Label for each vintage.
