The real decision gets made the day the QR code goes to print. From then on it sits on glass that moves into retail and stays there for years. What that code resolves to, who controls the data behind it and whether it still works in ten years, you settled all of that the moment you picked your provider.
That is why many people start by looking for the cheapest route. "Free wine e-label" is one of the most common searches around this topic, and the reflex makes sense. The obligation came from outside, it costs time, and it should not cost money on top of that. A free QR generator and a professional e-label provider look alike on day one. The difference shows up later, once your printed bottles are on the shelf and you can no longer change anything about the code, which is how a free label can end up costing more than it first appears.
A serious provider shows itself in a short list of hard requirements, and you can check every one of them before the first bottle is labelled. Each one also carries a concrete cost when it is missing. If you are earlier in the process and still mapping out what matters in an e-label tool at all, our five factors for choosing an e-label tool covers that ground first. What follows here is the checklist for the day you actually choose.
Does the e-label stay reachable for as long as your wine is on the market?
The digital label has to stay reachable for as long as the wine is on the market and fit for consumption. That makes the shelf life of your wine the yardstick. For age-worthy wines that quickly runs to ten or fifteen years and more. A free service that gets switched off tomorrow does not meet that bar.
Regulation (EU) 2021/2117 has applied to wine since 8 December 2023. Since then, every wine placed on the market after that date has to make its nutrition and ingredient information digitally accessible. The European Commission's guidance (Notice C/2023/1190) ties that availability to the durability of the product: the information should be as clearly visible and accessible as the details on the physical label, across the period the wine normally stays drinkable. What that means in detail for your winery is something we set out in the changes to the EU labelling rules.
That product-based requirement is the harder test to pass. A fixed number is something a cheap provider can simply print on a page. A promise measured against the lifespan of your wine can only be kept by someone who runs the redirect for the long haul. A dead QR code on a bottle that is already sitting on the shelf is a breach of the labelling obligation, and it is one you cannot recall.
Does your e-label run on an open standard or a dead end?
A professional e-label resolves through GS1 Digital Link, the open standard that turns a QR code into structured, machine-readable product data. A proprietary redirect from a cheap tool depends on the provider. If they disappear, the access disappears with them, and your printed bottles lose their label.
GS1 Digital Link is the standard that encodes GS1 identifiers like the GTIN, the lot or the expiry date into a web address. GS1 itself describes it as the backbone of the move to 2D codes that carry product information, traceability and certificates. For you that means the data sits on open rails that other systems can read too. A private shortcode binds the same information to one single provider.
The EU's Digital Product Passport is expected to run on those same open rails, something the Union is working on through the Ecodesign Regulation. That is a separate, later strand of regulation with its own deadlines, and it is not a requirement for your wine label today. What it does mean is that betting on the open standard now builds on the ground the industry is heading towards anyway.
Can you change the destination without reprinting the code?
The printed code and the data behind it belong apart. A serious provider lets you adjust the destination of the redirect at any time, without touching the glass. When a correction or a new vintage depends on reprinting the labels, the tool has chained your data to the print run.
In practice this happens all the time. Maybe you refine a nutrition value, add an ingredient text for another market, or move your landing page. With a static code that points straight at a fixed address, each of those changes means printing new labels and scrapping the old ones, and in the worst case re-labelling stock you have already bottled. A dynamic code whose destination you change in the admin panel costs you two minutes. The difference adds up across every vintage you bottle.
Is the e-label accessible and in the language of your markets?
The rules ask for the digital information to be as accessible as a physical label, and in a language the person in that market understands. A buried PDF fails the accessibility test. A page in a single language hits its limit the moment you export into more countries.
The Commission notes in its guidance that the online information has to be as clearly visible and accessible as the details on the label, and that the mandatory information must not get mixed up with marketing or tracking. A PDF you first have to download and zoom into barely works on a smartphone, and not at all for screen readers.
On language, the number 24 keeps circulating. Regulation (EU) 1169/2011 asks in Article 15 for the language understood by consumers in the market where the wine is sold. Sell into several countries and you need several languages to match. That Glasswise covers every official EU language is a property of our product. What counts is the language of each market you sell into.
Who owns the data, and can you get back out?
This question is in no regulation. It belongs on your list anyway. Your product data should be yours, exportable at any time, and moving to another provider must not strand the codes you have already printed. Lock-in is a choice the provider makes, and you can turn it down.
No EU law prescribes an exit right or data portability for wine e-labels. That does not make the question any less important, because this is exactly where the quiet dependency forms. If your redirect lives on the provider's domain and you cancel, every printed code points at nothing the moment the provider flips the switch.
At Glasswise our position on this is clear: the data is yours, you can export it at any time, and the redirect stays live even if you cancel. That is our promise as a provider. You can test it by putting the same question to every provider: what happens to my codes on the day I leave. The answer separates the serious from the cheap. How a switch without reprinting actually works is something we walk through in our guide to changing e-label provider.
Does the obligation turn into a brand presence?
The QR code is the one point where the person holding the bottle actually lands with you. A professional provider makes that space yours, built with your branding and your story, so the scan happens under your name. A pure compliance tool leaves a generic page on someone else's domain.
The labelling obligation already means that everyone who buys your wine scans your code. What they see next decides whether that moment works for you. A provider that couples the redirect to your branding turns a legal requirement into a genuine point of contact with your audience.
The checklist: six requirements to test before you print
| Requirement | Why it matters | Warning sign with a cheap provider |
|---|
| Availability across the life of the wine | Mandatory information has to stay reachable for as long as the wine is on the market, often ten to fifteen years | Free service with no promise the redirect still runs tomorrow |
| GS1 Digital Link as an open standard | Machine-readable data on open rails, independent of any single provider | Proprietary URL shortcode that disappears with the provider |
| Destination changeable without reprinting | Corrections and new vintages without new labels | Static code that points at one fixed address |
| Accessible and multilingual | As accessible as the physical label, in the language of each market | Download-only PDF, single language |
| Data ownership and exit | Export at any time, redirect stays live after cancellation | Data on someone else's domain, no export and no path out |
| Brand presence instead of a data sheet | The scan becomes a point of contact with your audience | Generic page on someone else's domain |
The questions to put to every provider before you print
Before the first labelled bottle, you need a clear answer to six questions. Does the label stay reachable for as long as my wine is on the market? Does it run on GS1 Digital Link? Can I change the destination without reprinting? Is it accessible and in the language of my markets? Do I own the data, and can I get back out? And does the mandatory code turn into a presence that works for me?
A provider that stays calm on every one of these questions, and can show you the answer as well as state it, is worth the decision you make before you print. If you want to see how individual providers stack up in detail, our provider comparison lays it out. And if you want to see how Glasswise handles these six points, take a look at the features.
