Digital and QR-Code Food Labels: What's Allowed in the EU

What can QR codes add to a food label?

Key takeaway: QR codes are most useful for supplementary information that improves consumer access without displacing compulsory on-pack particulars.

A QR code can create a useful second layer of product information. For example, a food business might use one to provide:

• Detailed product-use guidance

• Recipes or preparation instructions

• Additional sourcing information

• Explanations of voluntary environmental information

• Additional languages

• Extended product specifications

• Consumer-support information

• Accessibility-enhanced digital content

Voluntary food information remains regulated. Under Article 36 of Regulation (EU) No 1169/2011, voluntary information must not mislead consumers, must not be ambiguous or confusing and, where appropriate, must be based on relevant scientific data. The European Commission confirms that voluntary information remains subject to these safeguards.

A digital channel is therefore not an unregulated marketing space simply because the content sits behind a QR code.

Practical example: an ordinary packaged snack

Suppose a manufacturer sells a packaged snack with a QR code linking to an extensive product page.

The QR page could provide recipes, sourcing explanations and supplementary product information. But the business should not remove the legally required ingredients and allergen information from the pack and replace it with the words “scan for ingredients”.

For the specific mechanics of allergen declarations, see Allergen Labelling on Prepacked Food: The EU Rules.

How does wine e-labelling work?

Key takeaway: Wine provides a clear EU example of lawful e-labelling because specific sector legislation expressly allows certain information to be supplied electronically.

Wine demonstrates why businesses must distinguish a specific legislative exception from the general food-labelling rule.

Regulation (EU) 2021/2117 amended the EU wine regime so that the nutrition declaration and list of ingredients became mandatory for relevant wine products, while permitting specified information to be supplied electronically. The rules entered into application on 8 December 2023.

Under the consolidated wine rules, a producer using the electronic option may:

• Limit the physical nutrition declaration to the energy value

• Supply the full nutrition declaration electronically

• Supply the ingredients list electronically

However, important conditions apply.

When the ingredients list is electronic, allergen information covered by Article 9(1)(c) of Regulation 1169/2011 must still appear directly on the package or attached label. The legislation also prohibits collecting or tracking user data through the electronic information mechanism and prevents the relevant electronic information from being displayed alongside sales or marketing material.

A practical wine-label structure

A compliant electronic arrangement may therefore look conceptually like this:

Physical bottle label

• Required product particulars

• Energy value

• Allergen information

• Clearly identified route to the electronic information

Electronic information reached through the QR code

• Full nutrition declaration

• Ingredients list

• No consumer tracking

• No sales or marketing material accompanying the regulated electronic information

The European Commission specifically identifies a QR code as an example of the electronic means that may be used for wine.

The crucial lesson for other food businesses is not that “the EU now allows digital labels”. It is that electronic substitution is lawful where the legislation governing that product specifically permits it.

Is the EU moving towards more digital food labelling?

Key takeaway: The EU is examining digital ways of communicating food information, but businesses should not treat possible future reforms as permission to remove mandatory information today.

Digital food information has been part of the European Commission's evidence-gathering work around food labelling.

The Commission's Joint Research Centre reviewed how consumers use information supplied through alternatives to conventional packaging labels, including websites and QR codes. One conclusion was that information requiring consumers to use an external tool, such as scanning a QR code, may be less immediately accessible than information presented directly in the shopping environment.

Digital means have also formed part of the evidence base surrounding the Commission's work on revising the Food Information to Consumers framework. The Commission's current public revision material focuses particularly on areas including front-of-pack nutrition information, nutrient profiles, origin information, date marking and alcoholic-beverage labelling.

As of 23 July 2026, there is no general amendment to Regulation (EU) No 1169/2011 that allows ordinary prepacked foods to replace all mandatory physical-label information with a QR code.

Businesses should therefore design against the law currently in force, not against anticipated digital-labelling reforms.

What is best practice for QR-code food labelling?

Key takeaway: Treat a QR code as a controlled extension of the label and subject it to the same disciplined approval process as packaging artwork.

A practical QR-code approval process should include the following steps.

1. Classify every piece of information

Before artwork is approved, determine whether each item is:

• Mandatory under Regulation 1169/2011

• Mandatory under sector-specific EU legislation

• Required under national rules

• Voluntary supplementary information

Do not move an item online simply because space on the pack is limited.

2. Establish the legal basis for any digital substitution

If mandatory information is to appear electronically instead of physically, identify the exact legislative provision allowing it.

The wine rules are an example. They should not be extrapolated automatically to biscuits, sauces, ready meals or other ordinary prepacked foods.

3. Test the physical label independently

Ask whether a consumer who never scans the QR code still receives every mandatory on-pack particular required for that product.

For ordinary prepacked food, the answer should generally be yes.

4. Control the QR destination

Treat the linked page as controlled content.

Good governance includes:

• Stable URLs

• Version control

• Named content owners

• Change approval

• Periodic link testing

• Records showing which digital version accompanied each packaging version

A QR code that later redirects to outdated, inconsistent or unrelated information can undermine the value of an otherwise carefully controlled label.

5. Keep digital information accessible

The code should be large enough and positioned so that consumers can scan it reliably. The destination should work on ordinary mobile devices and present information clearly without unnecessary barriers.

Do not make essential supplementary information dependent on an obscure application or complicated registration process.

6. Review privacy and marketing restrictions

This is particularly important where sector-specific legislation imposes conditions on electronic information.

For wine e-labelling, the statutory electronic information must not be used to track users and must not be displayed together with information intended for sales or marketing purposes.

7. Check language and national requirements

Regulation 1169/2011 requires mandatory information to appear in a language easily understood by consumers in the Member State where the food is marketed. Member States may require one or more official EU languages within their territories.

Country variations: The FIC Regulation creates the EU-wide framework, but language requirements, enforcement arrangements and certain nationally regulated information can vary between Member States. Businesses selling across multiple EU markets should therefore complete a market-by-market review rather than assuming one digital-label setup will satisfy every local requirement.

Pre-print QR label check

Before releasing packaging containing a QR code, confirm:

• Mandatory on-pack information has not been removed without a valid legal basis

• The physical label remains legible

• The QR code links to the approved destination

• Digital and physical information agree

• Voluntary information is accurate and not misleading

• Any sector-specific e-labelling conditions are documented

• Allergen information remains where legally required

• Relevant privacy restrictions are satisfied

• Language requirements have been checked

• The QR destination is included in document-control and review procedures

Stay ahead on food labelling requirements

Key takeaway: Digital innovation works best when it is built on a sound understanding of the underlying EU labelling rules.

QR codes can make food information richer and easier to update, but they do not remove the need to understand which particulars EU law requires on the physical pack.

Spanish Compliance Institute's Food Labelling Regulations Training covers the practical framework businesses need when creating, checking and approving food labels, including Regulation (EU) No 1169/2011 and key label-control requirements.

Stay ahead on labelling — build the knowledge needed to review both physical and digital food information confidently.

Sources and Methodology

Key takeaway: This article is based primarily on current EU legislation and European Commission guidance checked against the position applicable on 23 July 2026.

This article was prepared using the supplied search intent and editorial brief together with current primary and official EU sources. It distinguishes the general Food Information to Consumers rules from sector-specific wine provisions and does not assume that proposed policy changes are already law.

Principal sources consulted:

• Regulation (EU) No 1169/2011 on the provision of food information to consumers, particularly Articles 12–15 and the rules governing voluntary food information.

• Regulation (EU) 2021/2117, introducing updated wine ingredients and nutrition-labelling requirements and electronic-information options.

• Consolidated Regulation (EU) No 1308/2013, including the current rules for electronic wine nutrition and ingredients information.

• European Commission guidance on wine labelling, including the application of the electronic labelling provisions.

• European Commission Food Information to Consumers revision material and Joint Research Centre evidence concerning digital means of providing food information.