When does a wine become a "product" affected by digital labelling?

For still wines, the second fermentation in bottle is taken into account at the end of the alcoholic fermentation; for semi-sparkling and sparkling wines, for aromatised wines, The time when their production cycle comes to an end must be considered.

If I offer a bottling service for third parties, in the cellar or at home, am I responsible for the new information (Val.Energetico and QRcode) to be presented on the label?

The person responsible for the information on the label is normally the producer, or in any case the entity that will be indicated as "producer" for compliance and regulatory requirements even if it is on behalf of others.

My company has a website, can I generate QRCode that will direct to a data sheet, page or archive of data sheets on my site?

 The product tabs must be displayed without any action to be performed other than scanning the QRCode or searching for it through the URL on any browser. They must be available in all the languages of the European Community and contain all the information required by the legislation in force. Finally, no tracking of scanning devices is allowed, a problem that would arise if one were to use, for example, one of the many on-line machine translation services. So the answer is: it depends, provided that we are structured in an appropriate way and also face important 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 to my company or website?

Product sheets cannot contain advertising or pure marketing items. VARIOTAG has provided for the possibility of incorporating a product image or manufacturer’s logo and a "contact the manufacturer" button, which may host an internet site or an e-mail address. These forms are in all respects digital documents subject to regulation, therefore they must show with absolute fidelity, only and exclusively what is printed on the label, and what is required by the EU regulation in terms of: ingredients, nutritional values, Instructions for the disposal of separable components for all used packaging.

I realized that to use my site for digital label management is complicated, and probably too expensive. So what solutions are allowed to me to be in compliance with EU regulation 2117/2021?

To be in order, you can adopt several options that depend, in the case of wines, from issues of volume and useful spaces:

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 cost, for more structured companies).

3) Join a digital labeling service like VARIOTAG and solve all problems starting from 30 cents of Euro including taxes per day.

I have several years of the same product on the market, can I use the same QRCode?

Certainly, but only if the wine is identical in its characteristics and relevant data to its counterpart produced earlier. Otherwise, a new product card must be activated for each year.

What are the minimum dimensions of the QRCode to be placed on the label?

In order to ensure the printability and readability of QRCode regardless of the media and transfer technologies adopted, the indications of the Italian competent authorities are defined as follows: 12mm per side as minimum format for traditional QRCode, 16 to 20mm for QRCode that integrate a logo or a personalization inside. VARIOTAG suggests to proportioning the QRCode format according to the length of the URL (the web address of the page).

The address of the page (URL) that hosts the product sheet must be printed in the label next to the QRCode reference as proposed by VARIOTAG?

No, the URL is not mandatory, but VARIOTAG allows you to print the address of the page next to the QRCode in the label, with minimum footprint and allow access to the required information with any device even other than common smartphones.

But exactly what and how do I need to put on the label in order to be clear and compliant?

VARIOTAG provides each customer with the guidelines for creating the information box in which it will be inserted: the energy value E expressed in kcal and kjoules, the QRCode, the word "ingredients" and the URL of the page (optional but suggested). To ensure the readability of the information, the size of this box delimited by a thin frame is about 16mm in height for 25/28mm wide.

I have to program the print and enter the relevant values in the product sheet later, is it possible?

Of course, the QRCode directs the user to a page that he can add or modify at a later time. The information that will link this particular product to the respective QRCode is the alcohol content and the Energy Value. They must be indicated and printed on the label and therefore no longer digitally modifiable except through the intervention of our responsible person on specific request. In case of activation of a new incorrect product card it will always be possible to delete it and activate a new one.

First of all, what is meant by product/product sheet/QrCode, 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 that stage the product will have specific characteristics in terms of: classification, type, ingredients, alcohol content, total acidity and sugar residue. This set of values therefore defines a product, some of which such as the alcohol content and the energy value expressed in kjoules and kcal, should also be mentioned on the label.

Hence the equation: 1 product (typology + mix of values) = 1 product/QRCode sheet

This aspect is very important because it is consistent with the European regulatory principles of law 2117/2021 to protect the clarity of the mandatory information provided and the way in which they must be presented for a simple, direct and unambiguous reading by consumers.

Can I use the same information box (QRCode, Energy, URL) for several labels, displaying the same product sheet for all?

Of course, as long as it is the same product regardless of the packaging used, the vintage and the lots marketed over time.

What does the "information box" to be included in the label contain and how much space it takes?

The dimensions of the information container suggested by VARIOTAG are approximately 26 x 16 mm and can be modulated and positioned vertically or horizontally. The box is surrounded by a thin frame, inside they will appear: the QRCode (at least 12mm per side), the "INGREDIENTS" writing, the energy value E expressed in kcal and kjoules.

In the "info box" there is also a short internet address, what is it?

VARIOTAG has considered it necessary to consider the possibility of also displaying the internet address of the digital product card (https://qr.variotag.com/code/xxxxx), even in the label. This way you will always be able to consult the document on line when the QRCode may not be readable (damaged or printed in low quality) or if you do not have a QRCode reader because of a missing 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 should 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". Of course, for longer-lived wines, it can be kept active even beyond 10 years. VARIOTAG has no time limit, with the renewal of the profile the customer will be able to keep all the codes that he deems necessary for his business.

Just a curiosity, what does it mean that there must be no traceability of individual scans?

The answer is simple: if a consumer scans a QRCode to verify its content and view the product sheet, he will not be "chased" by any automated tool connected for commercial or advertising purposes. If you use external machine translation applications to link your website to, it will be very difficult to guarantee the minimum level of privacy required by EU Regulation 2117/2021.

Which data should I use to determine the average nutritional value and energy value (E)?

Through our calculator developed in collaboration with AEA food consulting and available free of charge to all Variotag customers within their own area, it will always be possible to calculate the energy value (E) and the average nutritional values per 100ml having available the alcoholic strength, the sugar content (glucose/fructose/sugars) and the total acidity (tartaric). These three values are normally highlighted by the usual wine analysis without the need to request additional reports.

Are the filling dosage and the shipping dosage added to "classic method" wines to be considered ingredients?

Where these elements are present in the finished product they shall be indicated in descending order in the list of ingredients.

How should packing and filling gases be indicated?

The packaging and filling gases must be labelled in two ways permitted by the EU regulation "bottled under modified atmosphere" or "may be bottled under modified atmosphere".

Is carbon dioxide (CO2) added to wine an ingredient?

Of course, when added it should 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 bear the words "bottled in modified atmosphere".

Is alcohol to be considered an ingredient of vermouth or other liqueur wines that contemplate the addition of alcohol in the production recipe?

Of course, and should be included in the list of ingredients in descending order.

If I make sparkling wine, do I have to specify all the ingredients used to make the wine and the ingredients added for the second fermentation after?

Example: Ingredients: Grapes, sucrose, acidity corrector: E 334, filling dose, shipping dose, antioxidant: sulphur dioxide

A Moscato wine with 5.5% vol. must indicate on the label and digitally indicate the expiry date inside the product sheet?

If already foreseen before the new EU regulation 2117/2021 there are no reasons to stop this practice. VARIOTAG has provided, for relevance of the data and completeness of information, the option that the expiry date can also be reported on the electronic label

Example: Ingredients: Grapes, sucrose, acidity corrector: E 334, filling dose, shipping dose, antioxidant: sulphur dioxide

A Moscato wine with 5.5% vol. must indicate on the label and digitally indicate the expiry date inside the product sheet?

If already foreseen before the new EU regulation 2117/2021 there are no reasons to stop this practice. VARIOTAG has provided, for relevance of the data and completeness of information, the option that the expiry date can also be reported on the electronic label