Nutritional Values
While the EU allows for some flexibility in energy and nutritional values, the details must still be accurate for each vintage. These tolerances, which specify acceptable ranges, are outlined in official EU guidelines.
Consistency Is Key for 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 e-Labels Without Breaking Compliance
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.
Why Creating a New QR Code for Each Vintage Is Safer
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.