Selling Wine in the UK After Brexit: Do You Need an E-Label?

If you produce or sell wine in the United Kingdom, or if the UK is one of several markets you serve alongside the EU, the rules differ from the EU's in ways that catch producers off guard. The EU introduced mandatory e-labels in December 2023. The UK did not follow. But the UK has its own requirements, and the differences matter.

This guide explains what UK wine labelling law actually requires today, where it diverges from EU rules, how to manage both markets efficiently, and what changes may be coming.

The UK After Brexit: A Separate Regulatory Path

When the UK left the European Union on 31 January 2020, and the transition period ended on 31 December 2020, the UK ceased to be bound by new EU regulations. This includes the wine labelling amendments introduced by Regulation (EU) 2021/2117, which mandated ingredients lists and nutrition declarations for wines from the 2024 harvest onward.

The UK retained much of the pre-existing EU food law through the European Union (Withdrawal) Act 2018, which converted EU legislation into domestic UK law as "retained EU law." For wine specifically, the governing framework is:

• The Wine Regulations 2011 (as amended) - the primary domestic legislation for wine labelling and composition in England and Wales, with equivalent regulations in Scotland and Northern Ireland
• The Food Standards Agency (FSA) - the body responsible for food labelling policy in England, Wales, and Northern Ireland
• DEFRA (Department for Environment, Food and Rural Affairs) - responsible for wine sector policy in England
• The Food Information Regulations 2014 - implementing the retained version of EU Regulation 1169/2011 (FIC) for general food labelling

The key point: the UK kept the food labelling rules that existed before the EU's 2023 wine-specific amendments. It did not adopt the new EU requirements for ingredients lists, nutrition declarations, or e-labels on wine.

What the UK Currently Requires on Wine Labels

UK wine labelling requirements are governed by a combination of the Wine Regulations 2011 and general food law. Here is what must appear on a bottle of wine sold in Great Britain (England, Scotland, and Wales):

Mandatory Information

• Alcohol by volume (ABV) - expressed as a percentage, with permitted tolerances
• Allergen declarations - specifically sulphites (sulfur dioxide or sulphites where concentration exceeds 10 mg/l), plus milk and egg products if used as fining agents. These must appear on the physical label with a "Contains..." statement
• Volume - the nominal volume of the product (e.g., 75 cl or 750 ml)
• Name and address of the bottler or importer - for wines imported into the UK, the name and address of the UK importer must appear on the label
• Lot number - a batch identification code preceded by the letter "L" (or clearly identifiable as a lot marking)
• Country of origin - required for wine
• Product designation - whether the product is "wine," "sparkling wine," etc.

What Is NOT Required (as of 2026)

• Full ingredients list - the UK does not currently require a complete list of ingredients on wine labels, unlike the EU
• Full nutrition declaration - the UK does not mandate energy value, fat, carbohydrates, sugars, protein, or salt information on wine labels
• E-label or QR code - there is no UK requirement to provide digital labelling through a QR code or any electronic format

This creates a meaningful gap between what the EU requires and what the UK requires. EU-bound wines must carry substantially more information than UK-bound wines.

Does the UK Require E-Labels? No, But That Could Change

As of early 2026, the UK has not adopted the EU's e-label or QR code requirement. There is no legal obligation for wines sold in Great Britain to carry a QR code linking to ingredients or nutrition information.

However, this does not mean the UK has closed the door on future labelling changes. The Food Standards Agency has been actively reviewing food labelling requirements across multiple product categories, including alcohol. Several developments are worth watching:

FSA Labelling Reviews

The FSA has conducted consultations on calorie labelling for alcoholic drinks and broader nutrition information requirements. While no binding rules have emerged specifically for wine as of early 2026, the direction of travel suggests the UK may eventually introduce some form of ingredient or nutrition disclosure for alcoholic beverages.

Industry Pressure

UK retailers, particularly major supermarket chains, increasingly ask suppliers for detailed product information beyond what the law requires. Some retailers already request allergen, ingredient, and nutrition data for their own product information systems, even if it is not legally mandated on the label.

International Trends

Beyond the EU, other markets including Australia and New Zealand are also moving toward greater transparency in alcohol labelling. The UK government is aware of this global trend and may align with it over time.

The practical takeaway: while e-labels are not required in the UK today, preparing for future requirements is worth doing now while there is no pressure. Producers who already have e-label infrastructure in place will be ahead if and when the UK introduces new rules.

The Northern Ireland Protocol: A Critical Exception

This is where many producers trip up. Northern Ireland is not the same as Great Britain when it comes to product regulations.

Under the terms of the Windsor Framework (which replaced the original Northern Ireland Protocol), Northern Ireland continues to follow EU rules for goods, including food and wine labelling. This means:

• Wine sold in Northern Ireland must comply with EU labelling requirements, including the ingredients list, nutrition declaration, and e-label provisions introduced by Regulation (EU) 2021/2117
• Wine sold in England, Scotland, or Wales follows UK-specific rules and does not need an e-label
• If you ship wine to "the UK" without distinguishing between GB and NI, you may need to comply with both frameworks

For producers who distribute across the entire UK market, including Northern Ireland, the safest approach is to label for the stricter standard, which is the EU standard.

The Dual-Market Challenge: EU and UK on One Label

Many wineries sell into both the EU and the UK. Running two entirely separate label designs for the same wine is expensive and operationally complex, especially for small and medium producers. The question is: can you design one label that works for both markets?

The answer is yes, and the QR code is the key.

Why a QR Code Works for Both Markets

• The EU requires the ingredients list and nutrition declaration, which can be provided via a QR-linked e-label
• The UK does not prohibit QR codes on wine labels; it simply does not require them
• A QR code on the label satisfies the EU requirement while doing no harm in the UK market
• UK consumers increasingly expect transparency and will use the QR code if it is there, adding value even without a legal mandate

Designing a Dual-Market Label

Here is a practical approach for a single label that covers both the EU and UK:

1. Include all UK mandatory elements on the physical label: ABV, allergens, volume, bottler/importer name and address, lot number, country of origin
2. Include the EU-required physical elements on the same label: allergen declarations (required by both), energy value with the "E" symbol (required by the EU)
3. Add a QR code linking to a compliant e-label that provides the full ingredients list and nutrition declaration as required by the EU
4. Include dual importer information if needed, as your EU importer and your UK importer may be different entities, and both addresses may need to appear on labels destined for their respective markets
5. Use a caption next to the QR code such as "Ingredients & nutrition information" to signal what it links to

This approach gives you one label design (or a very close variant) that is legally compliant in both markets, avoids unnecessary duplication, and provides a good consumer experience everywhere.

Practical Advice for Wineries Selling to Both EU and UK

Based on common questions and challenges, here are specific recommendations:

Label for the Stricter Standard

If you sell to both the EU and the UK, design your label to meet EU requirements. The EU rules are a superset of UK rules, meaning that an EU-compliant label will also satisfy UK requirements (with the possible exception of importer address details).

Get Your Importer Details Right

EU and UK importer details are a frequent source of confusion. Post-Brexit, a UK-based importer cannot serve as the EU importer of record, and vice versa. If you use different importers for each market, your label may need to show both addresses, or you may need a small variation between EU-bound and UK-bound labels.

Do Not Wait for UK Rules to Change

If you already produce e-labels for the EU market, extending them to cover UK sales costs nothing extra. The infrastructure is there. Waiting for the UK to mandate e-labels and then scrambling to comply is riskier than simply being prepared now.

Keep Northern Ireland on Your Radar

If there is any chance your wine reaches Northern Ireland, even through a distributor or wholesaler who covers the whole UK, treat it as an EU-regulated market for labelling purposes.

Frequently Asked Questions

Is an e-label legally required for wine sold in England, Scotland, or Wales? No. As of 2026, there is no UK legal requirement for wine e-labels, QR codes, ingredient lists, or full nutrition declarations on wine sold in Great Britain. The UK's Wine Regulations 2011 and Food Information Regulations 2014 do not include these requirements.

Does Northern Ireland require e-labels on wine? Yes. Under the Windsor Framework, Northern Ireland follows EU rules for goods including wine. Wine sold in Northern Ireland must comply with EU Regulation 2021/2117, which includes the ingredients list, nutrition declaration, and the option to provide these via an e-label QR code.

Can I put a QR code on wine labels sold in the UK even though it is not required? Absolutely. There is no prohibition against including a QR code on UK wine labels. It is voluntary, but it adds transparency and consumer value. Many UK retailers and consumers appreciate having access to detailed product information, and it future-proofs your label for potential regulatory changes.

Will the UK adopt e-label requirements in the future? There is no confirmed timeline, but the Food Standards Agency has been reviewing alcohol labelling requirements, and the broader trend globally is toward greater ingredient and nutrition transparency. Producers who prepare now will be in a stronger position if and when new rules are introduced.

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Making One Label Work for Both Markets

The post-Brexit labelling split between the EU and the UK creates a real challenge for wine producers, but it has a straightforward solution. Design your label to meet EU standards, add a QR code, and you are covered in both markets, plus Northern Ireland.

One e-label covers the EU, the UK, and Northern Ireland. Create yours at scanthiswine.com.