Bottlebooks recommends you create a new QR code per vintage.
In some cases, it is possible to use the same QR code for multiple vintages. However, you need to be careful when doing this as there are many ways you could create illegal e-labels. Here is a guide to do so in Bottlebooks.
Strategies
Notes: A QR code is the physical code you print on your label that is a visual representation of a website URL. Taking a photo scan of a QR code takes users to an e-label, the mobile-ready website that contains all the legal information about your wine.
There are four strategies to take around QR codes and e-labels for new vintages.
New QR and e-label per vintage
RECOMMENDED
Bottlebooks recommends that you create a new QR code and e-label for each vintage, size and wine. Bottlebooks recommends this strategy for a number of reasons:
Avoid many of the potential legal issues you could have. See below in Key Legal Factors.
The best practice for GS1 Digital Sync.
Easy to create an e-label from an older vintage in Bottlebooks.
Easier to manager your product data and QR codes.
New QR per vintage, one e-label for all vintages
AVAILABLE IN BOTTLEBOOKS
Some wineries are creating a new QR code every vintage, but pointing to the same e-label. This allows them to comply with GS1 Digital Sync best practices. They must adhere to all the key legal factors below. If they legally need a new e-label, they are able to do so easily by directing a vintage to a different e-label. Follow this help guide for more information
One QR code and e-label for all vintages
AVAILABLE IN BOTTLEBOOKS
Creating one QR code for every vintage is possible if you are very careful about maintaining legal labels. See the key legal factors below. This process takes a great understand of the rules in all the countries you will be selling in.
One QR code to multiple e-labels (one per vintage)
NOT ALLOWED
This is strictly forbidden for a number of reasons:
Users should not see two sets of legal information.
User must not need to click to see information after scanning, such as choosing the vintage.
Key legal factors
Below are some of the key legal factors to consider when using the same QR code for multiple vintages:
The main principle is that when the consumer scans the QR code, they must see a legal ingredient and nutritional table. Vintage identification is not required.
So far, only the German and Austrian regulators have confirmed this. Other EU regulators have not yet confirmed this and it may not be legal in those countries.
Multi-information e-labelling is not allowed. Consumers cannot see two or more ingredient lists and nutritional tables. They must not have to click or download to see the information. It is therefore forbidden to list several vintages with different information.
The nutritional tolerances for energy and in the nutritional table are generous but each vintage must be accurate. The tolerances can be found in this EU document on tolerances.
You cannot add or remove ingredients from vintage to vintage. There is an exception for stabilisers and acidity regulators where you can add potential new ingredients in an "and/or" statement.
Updates to the e-label made for newer vintages are not allowed, if they make the older vintages that are already using the QR Code non-compliant. Adding (without the and/or statement) or removing ingredients, or changing the nutritional table (to values outside the tolerance for all vintages) will make older vintages non-compliant, even if they are not sold but only consumed.
If you are using GS1 Digital Link (embedding your GTIN code in the QR code) and you have a new GTIN per vintage, then you need to create a new e-label. Learn more about GS1 Digital Link
If you add additional information to the e-label, please ensure it is not vintage dependent.
This it not legal advice, please consult a lawyers or regulators for clarity.
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