The European Union has recently released comprehensive guidelines and clarifications regarding the wine labeling requirements for 2023, offering guidance for wine producers across member states. These new regulations, set to be enforced from December 8, 2023, will significantly impact the labeling practices of wine and wine-related products.
The document contains 40 answers addressing the most commonly asked questions about EU wine labeling requirements. It provides the much-needed clarity that many wineries have been waiting for and further explains essential details about the legal interpretation of EU 2021/2117 and related regulation EU 1169/2011.
Find the simple way to comply with wine label regulations with our easy-to-follow guide!
Key Highlights of the EU Wine Labeling Updates
- Implementation Timeline: Contrary to previous announcements, the EU Commission published an article on December 7th, declaring that the new regulations are set to be applied to all wines and wine products harvested from 2024 onwards. However, wines produced before December 8, 2023, will remain exempt until their stock is depleted.
- Definition of ‘Produced’: The European Commission has redefined the term ‘produced’ concerning wine products. According to the updated definition, a wine product is considered ‘produced’ when it meets the specific characteristics and requirements outlined in the regulations (more information on the subject is available further in the article and the comprehensive EU guidelines).
- Ingredient List & Nutritional Declaration: The regulations mandate that the ingredient list and nutritional declaration must be clearly visible on the physical label. For wines that employ electronic labeling, such information can be accessed via a QR code. Allergens and intolerances must be prominently displayed, ensuring consumer safety.
- Labeling of Sparkling Wines: Specific regulations have been introduced for sparkling wines, emphasizing the secondary fermentation process and other unique characteristics.
- Electronic Labeling: The new provisions allow for the use of electronic labels, particularly QR codes, to convey essential information. However, strict guidelines dictate the design, visibility, and accessibility of such electronic labels.
- QR Code: When printing a QR code on a physical label above the QR code itself, it is necessary to print the information “ingredients” to indicate what the user can expect when scanning the QR code.
Let’s delve deeper into the details to clarify the updated regulations.
Compulsory Information on Wine Labels: An Updated Guide
In the ever-evolving landscape of consumer rights and transparency, the presentation of information on wine labels has become a focal point for regulators and producers alike. Understanding these requirements is pivotal for ensuring compliance and building trust with consumers. This new compulsory information that must be incorporated into wine labels.
How should the new compulsory information be presented on the label?
- Key Elements Within the Field of View
To enhance consumer clarity and accessibility, most of the essential information must be displayed within a single “field of view” on the physical label. These key elements include:
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- Ingredient List & Nutritional Declaration: This gives consumers crucial details about what goes into the wine and its nutritional value.
- QR Code Option: The ingredient list and nutritional declaration can be presented via a QR code.
- Wine Category: Clearly indicating whether the wine is red, white, rosé, etc.
- Alcohol Percentage: Offering insights into the wine’s strength.
- Provenance/Origin Indication: Informing consumers about the wine’s geographical origin.
- Bottler’s Name: Giving credit to the entity responsible for bottling the wine.
- For Sparkling Wines: The name of the producer or vendor becomes vital for sparkling wine enthusiasts.
- Energy Value: Providing information about the wine’s caloric content.
- Allergens & Intolerances: These must be highlighted and clearly visible.
- Information Outside the Field of View
While the above elements must be within the primary field of view, certain details can be placed outside this area. These include:
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- Importer Details: Information about the entity importing the wine.
- Lot Numbers: Crucial for traceability and quality control.
- Minimum Durability Date: Commonly known as the ‘best before’ date, this guides consumers on the wine’s shelf life.
- Clarity on Nutritional Declarations Across Packaging
Regardless of the packaging – be it tank, keg, barrels, or the final bottled form – wines must provide consumers with the necessary nutritional declaration and ingredient list. The packaging at the point of purchase should always have this information, ensuring consistency and transparency.
- Defining the Production of Wine
Understanding when a wine is considered “produced” is pivotal for regulatory adherence. The timeline for wines and sparkling wines varies:
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- Wines: Considered produced once the primary alcoholic fermentation concludes, and the wine achieves the required alcoholic strength and acidity levels.
- Sparkling Wines: Their production is deemed complete after the second fermentation process.
- Defining Ingredients in Wine
At its core, an ingredient is any product that is present in the final product. This means that while processing aids and other components utilized during the manufacturing process play crucial roles, they don’t necessarily have to be listed if they aren’t found in the finished product.
Take wine, for instance. The primary ingredient of wine is grapes. However, there are specific variations within this category that can be specified:
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- Grapes,
- Crushed grapes,
- Grape must.
It’s worth noting that while these specifications exist, they aren’t mandatory. The essence is to provide clarity without unnecessary complications.
- Formatting the Ingredient List
To ensure consumers can easily identify what’s in their food or beverage, ingredient lists must follow a standardized format:
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- Title: Begin with a clear name of the functional (ingredient) category, stating “ingredients.”
- Order: Ingredients should be listed in descending order of weight. However, if an ingredient constitutes less than 2% of the total product, its order becomes flexible.
- Specific Names: Ingredients should be named by their specific name. As mentioned before: if the ingredient present can cause allergies or intolerances, it must be emphasized. There are exceptions, however, especially in regulations like the FIC Regulation and Delegated Regulation (EU) 2019/33. For instance, the term “grapes” can be used to denote the raw material rather than the specific ingredient name.
- Allergens and Labeling
Allergens, substances that can trigger allergic reactions or intolerances, demand special attention. They must always be declared on both physical and electronic labels. Specifically, the word “contains” should precede the allergen declaration, which must stand out through distinctive typography, such as bolding, different fonts, or contrasting colors.For example: “contains Sulphites.”
- Additives, Processing Aids, and Substances for Enrichment
When it comes to classifying additives, processing aids, and enrichment substances:
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- Additives and Enrichment Substances: These are recognized as ingredients since they are present in the final product. Consequently, they should be listed accordingly.
- Processing Aids: These don’t qualify as ingredients since they don’t end up in the final product. However, if these aids can potentially cause allergies, they still need inclusion in the ingredient list. A classic example is yeasts, which, though crucial in processes like fermentation, aren’t typically categorized as ingredients.
For those seeking a detailed breakdown of additives and processing aids, Delegated Regulation (EU) 2019/934 provides a comprehensive reference in Table 2 of Part A of Annex I.
- Ingredient and Procedure Regulations in Wineries
Here’s a comprehensive guide on the rules governing specific ingredients and procedures in the winemaking industry:
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- Sugar for Enrichment:
Sugar serves as a crucial component in winemaking, and its source determines its labeling.
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- Concentrated Grape Must & Rectified Concentrated Grape Must: These can be amalgamated and presented on labels as “Concentrated grape must.”
- Sucrose: When sucrose is used, it must be distinctly listed. Its designation on labels should be straightforward, such as “sugar.”
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- Yeast in Winemaking:
Yeast, a vital microorganism in the fermentation process, has specific labeling requirements.
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- Yeast Inclusion: Generally, yeast is deemed a processing aid and thus doesn’t necessitate inclusion in the ingredient list. However, an exception exists for yeast mannoprotein, which must be clearly stated if utilized.
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- Bottling and Packaging Gases:
Packaging methods can influence the longevity and quality of wine.
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- Protective Gases: When protective gases are utilized to enhance durability, their specification isn’t mandatory on labels. Nevertheless, a crucial note must be present: “packaged in a protective atmosphere.”
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- Nutritional Declaration:
Consumer awareness about nutritional content is rising, making accurate nutritional labeling indispensable.
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- Visibility and Font: Wineries must ensure that nutritional values and ingredient lists are conspicuous. Specifically, any textual representation of nutritional values should be a minimum of 1.2mm in size, irrespective of font style.
- Format:
- Tabular Format: Ideally, the nutritional declaration should be in a tabular layout, either on the physical label or its electronic counterpart.
- Linear Format: In instances where space constraints arise, wineries have the flexibility to present the nutritional declaration linearly.
- Content: Regardless of format, the nutritional declaration should encompass:
- Energy
- Fat
- Of which saturates
- Carbohydrates
- Of which sugars
- Protein
- Salt
When the amount of nutrient information is negligible or shown as “0”, the information can be shown in a statement of: “contains negligible amount of “X”.
Furthermore, the numerical representation of these nutritional values should align systematically, denoting values both per serving portion and per 100ml.
When the nutritional values are made available via an electronic label, the physical label must include a statement of energy values. This energy value can be expressed in a statement of the letter “E” followed by the value.
Example: E: 195Kj/47kcal per 100ml
- Is it necessary to include any other component besides fat, saturated fat, carbohydrates, sugars, protein, and salt in the nutrition declaration?
Beyond the widely recognized components like fats, saturates, carbohydrates, sugars, proteins, and salt, several other nutrients may be mandatory to declare. These include:
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- Mono-unsaturates,
- Polyunsaturates,
- Polyols,
- Starch,
- Fibre,
- Vitamins and minerals listed in point 1 of Part A of Annex XIII, provided they are present in significant amounts as defined in point 2 of Part A of the same Annex.
- Variability in Wine Products
Wine, due to its natural and batch-dependent nature, poses a unique challenge. The energy values of wines can differ from batch to batch. To address this, wineries are required to provide an “average value” that encapsulates the nutrient content across different batches. This value is derived considering:
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- Manufacturer’s analysis,
- Average values stipulated by the European commission in Annex XIV of the FIC Regulation,
- Generally accepted data.
However, it’s crucial to understand that while these values are representative, they may not always align perfectly with the actual nutritional content due to inherent variabilities. To account for these permissible differences, the European Commission has established tolerance values.
Note: The alcohol content, unlike other components, must always be precise.
- Electronic Labeling
With technological advancements, there’s a growing acceptance of electronic labeling methods. The European Commission permits certain data to be added electronically via data carriers attached to physical labels. The predominant method? QR codes, which have been explicitly acknowledged by the Commission.
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- Electronic Labeling Requirements
While the Commission hasn’t prescribed specific software or hardware for electronic labels, there are fundamental prerequisites:
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- The data carrier on the label must be:
- Easily visible
- Clearly legible
- Indelible
- If using a QR code sticker, ensure it’s non-removable.
- Above the QR code, include a statement of “ingredients”.
- The QR code should not have a mere “I” logo inside; it must provide comprehensive information.
- The data carrier on the label must be:
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Additionally:
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- The data should be accessible universally (e.g., via smartphones).
- It shouldn’t contain marketing data.
- Data collection, especially personally identifiable information, is strictly prohibited.
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- Integrating Marketing and EAN Information
While QR codes primarily serve for mandatory information, there are provisions for integrating additional data:
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- EAN Information: While adding EAN (European Article Number) data is permissible, it shouldn’t compromise the visibility or accessibility of mandatory nutritional and ingredient details.
In alignment with EU regulation 2021/2117, any wines produced post-December 8, 2023, must adhere to these specifications. This mandate underscores the importance of staying updated and compliant with evolving regulatory frameworks.
Implications for Wine Producers
The updated regulations necessitate a thorough review and potential revision of existing labeling practices by wine producers. Adherence to these requirements is crucial not only for regulatory compliance but also for maintaining consumer trust and ensuring product transparency.
Craft Technology e-labels offer a viable solution for wine producers, simplifying the process of compliance with evolving regulations. These electronic labels facilitate real-time updates, ensuring that producers remain abreast of any future changes in labeling requirements.
Find the simple way to comply with wine label regulations with our easy-to-follow guide!
Conclusion
The EU’s latest clarifications on wine labeling requirements underscore the importance of transparency, accuracy, and consumer safety in the wine industry. As these regulations come into effect, wine producers must prioritize compliance, leveraging technological solutions like Craft Technology e-labels to navigate the evolving landscape of regulatory requirements effectively.
For comprehensive details on the EU wine labeling regulations and guidance on compliance solutions, producers are encouraged to consult relevant resources and seek expert advice.
