Supply chain and check duties

For imported wines, check duties depend on the role in the supply chain.

When wine comes from outside the EU, importers, wholesalers, and retailers carry different responsibilities. This page maps those duties along the supply chain and shows which points each role typically secures.

Start checkOpen e-label guide
Legal classification

The check duties are distributed by market stage.

When wine is imported from a third country, first responsibility lies with the importer established in the EU as the first marketer. That importer must ensure that the digital landing page is reachable via the QR code and that mandatory information is provided correctly.

Wholesale and retail then check within their duty of care whether the delivered product and the digital content fit together. If issues arise, state control typically starts at the importer, trade partner, or warehouse level.

1. Main responsibility
Importer as first marketer in the EU
For the importer, the core task is to provide the e-label for the EU market and secure the factual quality of the content.
  • Every batch needs a working QR code on the back label.
  • The digital platform should remain ad-free and must not use marketing or tracking cookies.
  • Ingredients and nutrition values must be available in the official languages of the respective EU destination countries.
2. Goods receipt
Wholesaler with commercial duty of care
The distribution partner performs spot checks to confirm that delivered goods comply with EU labeling rules before they move further into the market.
  • Check the labeling and QR code at goods receipt on a sample basis.
  • Do not resell the wine to retail if errors are detected.
  • Treat incomplete e-label pages as an acquisition risk.
3. Sale to consumers
Retailer in store and web shop
The retailer carries a dual check duty: in the web shop before purchase and in physical retail at goods receipt.
  • In the web shop, ingredients and nutrition values must already be visible before purchase.
  • In store, the QR code should be physically present and readable.
  • For digital content, the retailer depends on timely data from the importer.
4. State control
Authorities and food monitoring
Faulty e-labels are often found during routine controls in trade or in wholesale warehouses.
  • Checks are carried out by state wine inspectors or the food supervision bodies of the federal states.
  • In case of violations, the EU-based importer is usually the main point of contact.
  • As first marketer, the importer remains the central contact for the EU market.
Practical check questions

These points should be clarified along the chain before further distribution.

Is the QR code present and readable on the back label?
Without a working code, the digital landing page is not reliably reachable for the market.
Is the e-label page complete and free from ad or tracking elements?
The digital platform should contain only the relevant mandatory information and avoid unnecessary tracking mechanisms.
Are ingredients, nutrition values, and language versions consistent for the destination country?
Especially for non-EU imports, the information must be prepared cleanly and understandably for the EU target markets.
Who is first addressed by authorities when errors are found?
The regulatory response usually goes through the EU-based importer as first marketer.
Next step

If needed, the contractual allocation of liability can be refined further.

The next professional layer is the contractual risk allocation between wholesaler and retailer in case of labeling errors. This page first maps the market stages and the state perspective.

Start checkOpen e-label guide

Note: This page classifies check duties for professional use only and is not legally binding.