VARIOTAG is a product of Z2F Srls | VAT IT02980080903 | Privacy and Cookies
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Frequently Asked Questions
When does a wine become a “product” subject to digital labeling?
For still wines, upon completion of alcoholic fermentation; for sparkling and semi-sparkling wines, the second fermentation in the bottle is taken into account; for aromatized, fortified, and dealcoholized wines, the moment when their production cycle is completed must be considered.
If I offer a bottling service for third parties, in the winery or at home, am I responsible for the new mandatory information (Energy Value and QR Code) that must be presented on the label?
The person responsible for the information on the label is normally the manufacturer, or in any case the entity that, for compliance and regulatory obligations, will be indicated as the “manufacturer” even if acting on behalf of others.
My company has a website, can I generate QR Codes that link to a technical data sheet, a page, or an archive of technical data sheets contained on my site?
The product sheets must be displayed without any action required other than scanning the QR Code or searching for it via the URL on any browser. They must be available in all European Community languages and contain all mandatory information in the manner required by current regulations. Finally, no tracking activity of the devices performing the scans is allowed, an issue that would arise, for example, by using one of the many online automatic translation services. So the answer is: it depends, as long as you are properly structured and prepared to face significant costs. The service offered by VARIOTAG is the most effective, immediate, and economical solution that can be adopted.
Can the product sheet contain information or links that refer to my company or my website?
Product sheets cannot contain advertising or purely marketing elements. VARIOTAG has established that it is possible to integrate a product image or the manufacturer's logo and a "contact the manufacturer" button, which can host a website or an email address. These sheets are in all respects digital documents subject to regulations, therefore they must report with absolute fidelity, solely and exclusively, both what is printed on the label and what is required by the EU regulation regarding: ingredients, nutritional values, disposal instructions for separable components for all packaging used.
I understand that using my site for managing digital labels is complicated, and probably too expensive. So what solutions are allowed for me to comply with EU Regulation 2117/2021?
To be compliant, several options can be adopted which, in the case of wines, depend on issues of bulk and available space:
1) Print everything on the label (requires a lot of space/no possibility of modification).
2) Purchase business management software that includes this new service (high costs, for more structured companies).
3) Join a digital labeling service like VARIOTAG and solve all problems starting from 30 euro cents per day including taxes.
I have several vintages of the same product on the market, can I use the same QR Code?
Certainly, but only if the wine is identical in its characteristics and relevant data to its previously produced counterpart. Otherwise, for each vintage, a new product sheet must be created.
What are the minimum dimensions of the QR Code to be placed on the label?
In order to ensure the printability and readability of QR Codes regardless of the media and transfer technologies used, the guidelines of the competent Italian authorities are defined as follows: 12 mm per side as the minimum size for traditional QR Codes, and from 16 to 20 mm for QR Codes that integrate a logo or customization inside.
VARIOTAG suggests proportioning the size of the QR Code according to the length of the URL (the internet address of the page).
Should the address of the page (URL) hosting the product sheet be printed on the label near the reference QR Code as proposed by VARIOTAG?
No, the URL is not mandatory, but VARIOTAG allows you to also print the page address next to the QR Code on the label, with minimal space usage, and to allow access to the mandatory information with any device, not just common smartphones.
But exactly, what and how should I include on the label to be clear and compliant?
VARIOTAG provides each customer with guidelines for creating the information box in which the following must be included: the energy value E expressed in kcal and kjoule, the QR Code, the word “ingredients” and the URL of the page (optional but recommended). To ensure the readability of the information provided, the size of this box, outlined by a thin border, is about 16 mm in height and 25/28 mm in width.
Do I need to schedule the printing and enter the relevant values in the product sheet at a later time, is it possible?
Of course, the QR Code directs the user to a page that they can integrate or modify even at a later time. However, the information that will bind that specific product to its respective QR Code are the alcohol content and the Energy Value. These must be indicated and printed on the label and therefore can no longer be digitally modified except through the intervention of one of our managers upon specific request. In the event of activating a new product sheet with errors, it will always be possible to delete it and activate a new one.
First of all, what is meant by product/product sheet/QR Code, how is a "product" constituted and determined?
By product we mean a wine that has completed its production process (at the end of its first or second fermentation or at the end of its production practices) and is ready to be bottled and possibly marketed.
At this stage, the product will have very specific characteristics in terms of: classification, type, ingredients, alcohol content, total acidity, and residual sugar. This set of values therefore defines a product, some of which, such as alcohol content and energy value expressed in kilojoules and kcal, must also be indicated on the label.
Hence the equation: 1 product (type + mix of values) = 1 product sheet/QR Code
This aspect is very important because it is consistent with the European regulatory principles of law 2117/2021 to ensure the clarity of mandatory information provided and the ways in which it must be presented for a simple, direct, and unambiguous reading by consumers.
Can I use the same information box (QR Code, Energy, URL) for multiple labels, displaying the same product sheet for all of them?
Of course, as long as it is the same product regardless of the packaging used, the vintage, and the batches marketed over time.
What does the "information box" to be included on the label contain and how much space does it take up?
The dimensions of the information container suggested by VARIOTAG are approximately 26 x 16 mm and it can be adjusted and positioned vertically or horizontally. The box is outlined by a thin frame, and inside it must appear: the QR Code (at least 12 mm per side), the word “INGREDIENTS”, the energy value E expressed in kcal and kjoule.
A short internet address also appears in the "information box", what is it?
VARIOTAG has considered from the outset the need to also display the internet address of the digital product sheet (https://qr.VARIOTAG.com/code/xxxxx), also on the label. In this way, it will always be possible to consult the document online when the QR Code may not be readable (damaged or printed in low quality) or in the event that you do not have a QR Code reader due to a lack of connection on your smartphone or if you are in front of a computer. In any case, it is correct to point out that the URL on the label is not expressly required by EU Regulation 2117/2021.
How long must product sheets be available online?
According to the most common guidelines, at present, each card should remain active for a period of at least 3 years, that is, until the "end of the commercial life of a specific product." Naturally, for longer-lived wines, it can remain active for over 10 years. VARIOTAG does not set time limits; with the renewal of the profile, the customer can keep all the codes they deem necessary for their business operational.
A curiosity, what does it mean that there should be no traceability of individual scans?
The answer is simple: if a consumer scans a QR Code to verify its content and view the product sheet, they cannot be "tracked" by any automatic tool connected for commercial or advertising purposes. If you use external automatic translation applications to link to your website, it will be very difficult to guarantee that minimum level of privacy imposed and required by EU Regulation 2117/2021.
To determine the average nutritional values and the energy value (E), which data should I use?
Through our calculator, developed in collaboration with AEA food consultancy and available free of charge to all VARIOTAG customers within their reserved area, it will always be possible to calculate the energy value (E) and the average nutritional values per 100ml by having the alcohol content, sugar content (glucose/fructose/sugars), and total acidity (tartaric) available. These three values are normally highlighted by the usual wine analyses without the need to request additional reports.
Are the filling dosage and shipping dosage added to "classic method" wines to be considered ingredients?
When these elements are present in the finished product, they must be listed in descending order in the list of ingredients.
How should packaging and filling gases be indicated?
Packaging and filling gases must be indicated on the label in one of two ways permitted by the EU regulation: "bottled in a modified atmosphere" or "may be bottled in a modified atmosphere".
Is carbon dioxide (CO2) added to wine to be considered an ingredient?
Certainly, when added it must be indicated in the list of ingredients as "carbon dioxide." If the product is then also bottled with packaging gas, it will not be necessary to state "bottled in a modified atmosphere."
Should alcohol be considered an ingredient of vermouth or other fortified wines that include the addition of alcohol in their production recipe?
Certainly, and it must be included in the ingredient list in descending order.
If I produce sparkling wine, do I have to specify all the ingredients used to make the wine and the ingredients added for the second fermentation as well?
Example:
Ingredients: Grapes, sucrose, acidity regulator: E 334, filling dose, shipping dose, Antioxidant: sulfur dioxide
Does a Moscato wine with 5.5% vol. have to indicate on the label and digitally on the product sheet the expiration date?
If already provided before the new EU Regulation 2117/2021, there are no reasons to discontinue this practice. VARIOTAG has provided, for the relevance of the data and completeness of information, the option that the expiration date may also be included in the electronic label
VARIOTAG is a product of Z2F Srls | VAT IT02980080903 | Privacy and Cookies
Go to the DASHBOARD | Follow us on: FACEBOOK | Call us at +39 079 097 7300