General Overview

As of December 8, 2023, new EU regulations for wine labelling have come into effect, amending the existing rules. These changes are crucial for anyone involved in the wine industry, from producers to retailers, as they aim to ensure transparency and provide consumers with essential information about the wine they purchase.

The new regulations are part of Regulation (EU) 2021/2117, which updates the previous rules under Regulation (EU) No 1308/2013. This document aims to clarify these updates and assist businesses in complying with the new requirements.

Key Points

Relationship Between Regulations

The new wine labelling rules are linked with the general food labelling regulations outlined in Regulation (EU) No 1169/2011. This means that unless specified otherwise, the general food labelling rules also apply to wine.

Mandatory Information on Labels

Wine labels must now include both a nutrition declaration and a list of ingredients. This information must be clearly visible and legible, all within the same field of view, without the need to turn the container.
Essential details that must be on the label include:
Wine category (e.g., ‘de-alcoholised’ or ‘partially de-alcoholised’ if applicable).
PDO (Protected Designation of Origin) or PGI (Protected Geographical Indication) and their respective names.
Alcohol content.
Provenance (origin) of the wine.
Name of the bottler, producer, or vendor.
Net content.
Sugar content for sparkling wines.
Date of minimum durability for de-alcoholised wines.
If the nutrition declaration or the list of ingredients is provided electronically (e.g., via a QR Code), a link must be included on the label.

Electronic Labelling

While full nutritional information can be provided online, the energy value must still appear on the physical label.
Allergenic substances must be listed on the label even if other ingredients are provided electronically.

Application Timeline

The new labelling rules apply to all wines placed on the market after December 8, 2023. Wines produced before this date can continue to be sold under the old labelling rules until stock is exhausted.

Definition of ‘Produced’

A wine is considered ‘produced’ when it has gone through alcoholic fermentation and any other required oenological practices to meet the necessary characteristics (like alcoholic strength and acidity).
For sparkling wines, production includes the second fermentation that creates the required pressure and alcohol content.

Enforcement and Compliance:

Member States’ authorities are responsible for ensuring compliance with the new labelling rules. Wines produced before December 8, 2023, and imported wines in stock before this date are exempt from the new requirements.

Ingredients

General Presentation

The list of ingredients on wine labels must follow general rules set out in the FIC Regulation, as there are no specific rules just for wine. Here’s what you need to know:

Heading: The list must start with the word "Ingredients."
Order: Ingredients must be listed in descending order of weight as they were used in production. Ingredients that make up less than 2% of the finished product can be listed after the main ingredients in any order.
Names: Ingredients should be identified by their specific names, unless exceptions are provided in the regulations (e.g., "grapes" can simply be listed as such).

Additives and Processing Aids

Naming Additives: Additives should be listed with their functional category (e.g., "Preservatives") followed by their specific name or E Number.
Table of Additives: A full list of allowed additives and their categories can be found in Table 2 of Part A of Annex I of Delegated Regulation (EU) 2019/934.
Multiple Additives: For additives like acidity regulators and stabilizing agents, which might be interchangeable, you can use “contains... and/or” followed by up to three specific additives.

Allergenic Substances

Listing Allergens: All allergens must be listed in the ingredients if they are present in the final product. Allergens should be highlighted using a different font, style, or background color.
Electronic Labels: If ingredients are listed electronically, allergens must still be indicated on the package with the word "contains," followed by the allergen.
No Repetition: Allergens should not be repeated unless using an optional pictogram.

Special Cases

Enrichment Substances: Any substances added for enrichment that remain in the final product must be listed as ingredients.
Sugar: For enrichment, “concentrated grape must” can be used for concentrated grape must or rectified concentrated grape must. Sucrose must be listed separately as “sugar” if used.
Yeasts: Generally, yeasts do not need to be listed as they are considered processing aids. The exception is yeast mannoprotein, which must be listed if used as an additive.

Additional Details

Acidity Regulators and Stabilizers: Ingredients under 2% can be listed in any order.
Packaging Gases: If using packaging gases, you can state “Bottled in a protective atmosphere” instead of listing specific gases.
Main Ingredient: The main ingredient can be listed as "grapes," "crushed grapes," or "grape must" depending on what is used. Alternatively, "grapes" can cover all these variations.

Nutrition Declaration

How to Present the Nutrition Declaration

Format: The nutrition declaration must be presented in a table with aligned numbers if there is enough space. If space is limited, a linear format is acceptable. When presented electronically, it should always be in a tabular format.
Order: The required order of elements is: Energy, Fat (of which saturates), Carbohydrate (of which sugars), Protein, and Salt. Optional elements like polyols can be added but must follow specific rules.

What to Include in the Nutrition Declaration

Mandatory Elements: The declaration must include energy, fat, saturates, carbohydrate, sugars, protein, and salt.
Negligible Amounts: If any of these nutrients are present in negligible amounts, you can state "Contains negligible amounts of [nutrient]" near the nutrition declaration.
Optional Additions: You can add information on mono-unsaturates, polyunsaturates, polyols, starch, fiber, and certain vitamins and minerals if they are present in significant amounts.

Calculating Nutrient Values

Methods: Nutrient values can be based on:
Manufacturer’s analysis
Known average values of ingredients
Established data
Energy Calculation: Energy must be shown in both kilojoules (kJ) and kilocalories (kcal), with kilojoules listed first.

Tolerances for Nutrient Values

Average Values: The declared values should represent the average nutrient content, accounting for natural and seasonal variability.
Accuracy: The values should not be at the extremes of the tolerance range but should be accurate across multiple batches.

Character Size

Minimum Size: The font size for the nutrition declaration must be at least 1.2 mm, regardless of the format used.

Electronic Labelling

Providing Information via Electronic Means

Types of Electronic Means: The updated CMO Regulation doesn't specify a mandatory system or software for electronic labelling. It allows various electronic formats accessible through barcodes (e.g., QR Codes) on packaging.
Functionality: Electronic means used must not gather user data. They should provide universal access tools (like smartphones) a direct link to online information.
Visibility and Legibility: Information must be clearly visible on the package or label, easily readable, and not obscured by other elements. It must offer comparable access to what's physically printed on the label.
Use of QR Codes: QR Codes are permissible on labels to direct consumers to detailed nutrition and ingredient information.

Integration with Packaging

Attachment and Legibility: Labels with electronic information must be securely affixed to ensure accessibility and visibility. They should comply with EU legislation on legibility and durability.

Design and Accessibility

Formatting Rules: Electronic nutrition declarations must adhere to the formatting rules outlined in Article 34 of the FIC Regulation, ensuring clarity and consistency in presentation.
QR Code Placement: A QR Code should distinctly lead to essential information, avoiding ambiguity or misleading content. It should directly link to compulsory information without additional marketing content.

Compliance and Oversight

Responsibility: Member States are responsible for ensuring that electronic labelling complies with regulations, including the prohibition of user data collection and commercial messaging.

Long-Term Accessibility

Availability: Information accessed via electronic means, such as QR Codes, must remain accessible for the duration that the product remains suitable for consumption under normal storage conditions. Operators are accountable for maintaining accuracy and availability.