Why Your Wine E-Label Can't Track Users or Show Marketing

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Here is a trap that catches wineries setting up a wine e-label for the first time: pointing the QR code at their own website, or at a page with a "buy now" button and a newsletter sign-up. Under the EU rules, that does not comply.

The e-label has to be a neutral page

European Commission Notice C/2023/1190 is clear on this. The full nutrition declaration and ingredient list must not be displayed with information intended for sales or marketing purposes (Q30), and the page must sit in a neutral environment that does not engage the reader toward a purchase (Q36).

The Notice specifically says a wine producer's own commercial website typically does not comply, because it usually contains commercial information (Q30). So the natural instinct, "I'll just add a page to my winery site," is exactly the thing to avoid.

Direct access, no marketing detour

The machine-readable code must give direct access to the mandatory information (Q33). You cannot route the scanner through a splash page, an age gate that markets the brand, or a promotional interstitial before the ingredients and nutrition appear.

No tracking of visitors

The Notice states that the system used must not collect or track user data, and adds that there are no exceptions (Q26, Q35).

Compliance commentators generally read this as ruling out tracking analytics, cookies and tracking pixels on the e-label page. That reading is a reasonable interpretation; the no-tracking rule itself is what the Notice states, while the specific list of technologies is commentary rather than verbatim text. Either way, the safe approach is an e-label page that runs no visitor tracking at all.

How to stay on the right side of it

• Host the e-label on a dedicated page, separate from your sales website.
• Keep it to the mandatory information: ingredients and nutrition, in the market's language.
• Make the QR resolve straight to that page.
• Do not add cart links, promotions, sign-up forms or tracking to that page.

MyProductPassport hosts each wine on its own neutral passport page, separate from your commercial website, with a direct-access QR, which fits the way the Commission describes a compliant e-label.

Frequently Asked Questions

Can I link the QR to my winery's website?

No. The Commission Notice (Q30) says a producer's commercial website typically does not comply. Use a dedicated, neutral page instead.

Can I use Google Analytics on the e-label page?

The Notice says no user data may be collected or tracked, with no exceptions. The common reading is that this rules out analytics and cookies on the e-label page, though that specific technology list is interpretation rather than the exact wording of the Notice.

Want a neutral, dedicated e-label page without building one yourself? Create one free.