Starting from December 8th, 2023, all wines produced or sold on EU land will have to include nutritional and ingredient information on their labels using digital e-labels, due to new EU wine labeling requirements.
For winemakers, understanding these regulations is not just a legal obligation but a vital step toward preserving the integrity of their craft and avoiding penalties.
This article is intended to provide guidance to wine producers, distributors, and label producers who sell their wines in the European Union, on how to comply with the EU’s wine label regulations and avoid penalties.
Important points to remember for wineries.
- All wine sold in the European Union after December 8, 2023, must have allergy, energy, ingredient, and nutritional information on their labels.
- Intolerance, allergy, and energy information must be printed on the physical wine label. Ingredient and nutrition information can be accessed electronically via a QR code.
- It is imperative that the QR code does not redirect the consumer to a webpage that consists of marketing or sales information, or one that tracks users.
- QR codes offer multiple advantages, including simplifying compliance, enhancing reliability, and reducing costs.
What is an e-label?
An electronic label, commonly referred to as an e-label, represents an innovative solution for providing the information that EU regulations require.
Specifically, wine producers can utilize e-labels to furnish customers with vital details about the nutritional value or ingredients of their wines. The use of e-labels proves beneficial when the label on the bottle is insufficient in providing this information. This may be due to the limited space available or the need to maintain the design of the label.
As such, e-labels serve as a practical way of providing information to customers and complying with the regulations set forth by the EU.
What are the new EU wine label requirements?
The new requirements for labeling wine bottles in the EU can be summarized as follows:
- Each wine bottle sold within the EU must display a QR code linking to a webpage detailing its ingredients, allergen, energy, and nutrition information.
- This information has to meet strict guidelines, including translations into all 24 official EU languages.
- Distributing sales and marketing materials alongside the required information is not allowed and is considered a regulation violation.
- QR codes eliminate the need for costly physical label design and allow for real-time updates to landing pages.
After over a decade of discussions on how to improve transparency in the alcoholic beverage industry, the EU has introduced new legislation requiring winemakers to label their ingredients when selling wine within the EU. As mentioned above, according to Regulation (EU) 2021/2117, all wine produced after December 8, 2023, must display:
- energy, and
- nutrition information.
All allergens and intolerances must be clearly labeled or physically attached to the product. It is worth noting that certain crucial information, such as ingredients, can be disclosed through electronic means, such as a QR code.
In accordance with Regulation (EU) 1306/2013 Chapter IV, Article 89, it is required that any non-compliant wine must be removed from the market and may be subject to penalties.
A similar law is expected to be enforced in the US in 2024. However, the Alcohol and Tobacco Tax and Trade Bureau (TTB) will impact all wines sold on US soil.
Are you already familiar with the regulations and want to ensure complete compliance with the requirements for QR codes and wine e-labels? We recommend reading our comprehensive step-by-step guide to QR code wine e-label upload.
This guide offers step-by-step instructions to ensure that you are able to comply with these requirements in a timely and efficient manner.
Is there a legal basis requiring a wine producer to use the e-label?
Under the new EU wine labeling regulations, wine and aromatized wine producers are required to disclose the ingredients and nutritional information of the wine on the label.
The producers have the option to include this information either on the printed label itself or on a dedicated webpage accessible by scanning a QR code.
Managing and delivering this vast amount of data to customers in real-time is a challenge.
Craft Technology platform offers cost-effective e-label solutions for winemakers, rather than spending time and resources on their own solutions. We discussed the challenges and the pitfalls of in-house e-labeling in greater detail in this article. Be sure to read it to make an informed decision.
How to be compliant with EU wine label requirements?
To help comply with these new regulations, the industry professionals behind the Craft Technology platform will equip the winemakers and wineries with the necessary tools and knowledge to comply with these new regulations. Head to our step-by-step guide to QR code wine e-label uploads for compliance.
What are the consequences if a wine does not comply with the wine labeling rules of the EU?
Wine that does not comply with new labeling requirements of the EU will be removed from sale, and the government will be able to impose fines, in accordance with Regulation (EU) 1308/2013, Article 90a.
The EU expects member state governments to carry out checks on wines available in their markets and enforce the new requirements.
What is required to be shown on the wine label?
Starting from December 2023, wines sold in the EU will be required to provide detailed information on nutritional content, including energy value, and ingredients, such as flavorings, additives, enzymes, or any component of a composite ingredient.
This is in compliance with EU Regulation 2021/2117.
The following details must be clearly mentioned on the label itself:
- Category designation;
- Intolerances and allergens present;
- Actual alcoholic strength by volume;
- Provenance information;
- Name of the bottler; for sparkling wine, the name of the producer/vendor,
- Importer’s name (in case of imported wines);
- Sugar content (in the case of sparkling wine);
- Minimum durability date for de-alcoholized wine products having an actual alcoholic strength by volume of less than 10%;
- Lot number;
- Net quantity of the wine.
The limited space on traditional wine labels makes it difficult to include all the required information.
After taking into consideration the concerns expressed by the industry regarding the increased expenses and the potential for labels to become overcrowded with text, EU policymakers came to a mutually beneficial compromise.
According to this compromise, the label must include details regarding the energy value, as well as a clear indication of all ingredients that may trigger allergies or intolerances. It is important to clearly indicate potential allergens, such as gluten and casein, by using the word “contains”. The energy value should be accurately calculated for a standard 100ml serving and explicitly represented by the symbol “E”.
However, the comprehensive and complete list of ingredients and nutrition tables can be effectively delivered electronically, through a QR code, for example. It’s important for wine importers and other businesses to be aware of the rules related to ‘electronic labels.’
The information provided in these labels must be available in an official EU language that’s relevant to the consumer. EU states have the authority to determine which languages must be included.
Furthermore, the web pages linked by the QR codes can only display information that is legally required. It is prohibited to include any extra sales or marketing content when a customer scans the code and opens the page.
Additionally, electronic label systems must not track users or collect any data about them. The legislation requires wine businesses to update the labels on their bottles to meet the new requirements by December 8. However, to allow these businesses enough time to adapt, the wine bottles that have been produced before the deadline of December 8 can still be sold without any need for updating their labels.
Please note that these new regulations will be applicable to all 27 member states of the European Union.
A list of potential allergens and intolerances that must be printed on the bottle label if present in the product are:
- Cereals containing gluten, namely: wheat, rye, barley, oats, spelt, kamut or their hybridized strains, and products thereof, except (a) wheat-based glucose syrups including dextrose, (b) wheat-based maltodextrins (1); (c) glucose syrups based on barley; (d) cereals used for making alcoholic distillates including ethyl alcohol of agricultural origin;
- Crustaceans and products thereof;
- Eggs and products thereof;
- Fish and products thereof, except (a) fish gelatine used as a carrier for vitamin or carotenoid preparations; (b) fish gelatine or Isinglass used as a fining agent in beer and wine;
- Peanuts and products thereof;
- Soybeans and products thereof, except (a) fully refined soybean oil and fat (1); (b) natural mixed tocopherols (E306), natural D-alpha tocopherol, natural D-alpha tocopherol acetate, and natural D-alpha tocopherol succinate from soybean sources; (c) vegetable oils derived phytosterols and phytosterol esters from soybean sources; (d) plant stanol ester produced from vegetable oil sterols from soybean sources;
- Milk and products thereof (including lactose), except (a) whey used for making alcoholic distillates, including ethyl alcohol of agricultural origin; (b) lactitol;
- Nuts, namely: almonds (Amygdalus communis L.), hazelnuts (Corylus avellana), walnuts (Juglans regia), cashews (Anacardium occidentale), pecan nuts (Carya illinoinensis (Wangenh.) K. Koch), Brazil nuts (Bertholletia excelsa), pistachio nuts (Pistacia vera), macadamia or Queensland nuts (Macadamia ternifolia), and products thereof, except for nuts used for making alcoholic distillates including ethyl alcohol of agricultural origin;
- Celery and products thereof;
- Mustard and products thereof;
- Sesame seeds and products thereof;
- Sulphur dioxide and sulphites at concentrations of more than 10 mg/kg or 10 mg/liter in terms of the total SO2 which are to be calculated for products as proposed, ready for consumption, or as reconstituted according to the instructions of the manufacturers;
- Lupin and products thereof;
- Molluscs and products thereof.
What type of information can be provided from the QR code?
In compliance with regulatory requirements, the ingredient and nutritional information on wine labels is mandatory. However, this information can be made available to consumers through a Quick Response (QR) code printed on the wine label. The QR code, when scanned, directs the user to a webpage that hosts the relevant information.
It is imperative to note that e-label must not contain any information intended for sales or marketing purposes. The presence of any sales or marketing details alongside the mandatory ingredient or nutritional information would be deemed a violation of the relevant regulatory framework.
Our experts provided detailed instructions on how to disclose nutrition and energy information, including calculating energy values and organizing allergens, in the article about data collection for winemakers.
What is the language requirement for displaying information on the e-label?
The law requires making the information above available in an official EU language that is easily understood by the consumer. Additionally, E.U. member countries can specify the languages in which e-labels must be displayed.
What’s the deadline for EU wine label compliance?
According to the regulations, wine that has been produced prior to December 8, 2023, is exempt from the specified requirements and can still be sold in the EU after the date, until the stock runs out.
Currently, there is no official definition of the term “produced” in the context of winemaking. However, the wine industry is interpreting it as “completed fermentation in the barrel”. We will update this information as soon as an official definition becomes available.
Is creating webpages with information on each wine on your wine brand’s website compliant?
It is important to note that creating web pages with information on each wine on your website carries the risk of non-compliance with several laws.
We extensively covered this topic. This article explains in great detail why wineries should think twice before doing e-labeling on their own.
Should low-alcohol or dealcoholized wine labels be in compliance with regulations?
Wines that have undergone a process to dealcoholize or to lower their alcohol content are regulated similarly to alcoholic wines. However, certain distinctions exist depending on the amount of alcohol present in the beverage.
If the alcohol by volume is no more than 0.5%, the term “de-alcoholized” should be included in the description.
If the alcohol by volume is higher than 0.5% For wines that have been dealcoholized to less than 10% ABV, regulation (EU) 2021/2117 states:
- The minimum product durability must be stated on the physical label and may also be provided electronically.
- Wines with less than 0.5% ABV must use the term “de-alcoholized”.
- For wines above a 0.5% ABV, the term “partially de-alcoholized” can be used. The term can be provided digitally.
The new regulation, finalized on May 30, 2023, mandates the declaration of the minimum product durability or expiration date for wines with less than 10% ABV, starting on December 8, 2023.
Should aromatized wine labels be in compliance with regulations?
The EU’s new regulations for wine labeling require that aromatized wine produced after December 8, 2023, must disclose ingredients, nutritional information, and other details. These details can be presented either on the physical label or through electronic means such as QR codes.
Benefits of wine e-label solutions for winemakers
Wine e-labels provide several benefits for winemakers in today’s digital age.
- Cost-efficiency: E-labels eliminate the costs associated with printing, designing, and applying traditional paper labels, saving winemakers money on production expenses.
- Consumer engagement: E-labels allow winemakers to provide interactive and detailed content, enhancing consumer engagement and creating a more immersive wine-buying experience.
- Transparency: E-labels enable winemakers to share comprehensive information about the wine, including its origin, ingredients, and production methods, fostering transparency and building trust with consumers.
- Traceability: E-labels facilitate better traceability, allowing consumers to verify the wine’s authenticity and origin through digital platforms, reducing the risk of counterfeit products entering the market.
- Sustainability: By eliminating the need for paper labels, e-labels contribute to environmental sustainability by reducing paper waste, and aligning with eco-friendly practices and consumer preferences.
Why are EU wine labeling rules good for winemakers?
Wine bottle labels are a critical tool for wine producers to communicate with their customers. These labels serve as a direct and immediate means of expressing the brand’s personality, providing information about the wine’s taste, and distinguishing the product in a highly competitive market.
The EU wine bottle labeling regulations are highly beneficial for winemakers for several reasons. The European Union (EU) wine bottle labeling rules play a crucial role in ensuring
- quality, and
- consumer protection within the European wine market.
By prioritizing transparency and easy access to information, winemakers can build trust with their customers and demonstrate their commitment to safety and quality.
The use of clear and accurate e-labeling via QR code, is an essential component of this effort, as it helps consumers make informed decisions about the products they purchase.
What are the benefits of using the e-label solution to display the required information?
E-labels and QR codes are a suitable solution for winemakers to comply with EU regulations. They provide crucial benefits for wine producers, such as:
- The QR code allows automatic translation of the label into the customer’s preferred EU language.
- E-labels offer the advantage of real-time updates, allowing for swift and efficient correction of any errors noted after label creation.
- The QR code on the label takes up minimal space, maintaining the design while providing consumers with the requested information.
In this article, you can find detailed information about why winemakers should use QR codes to comply with EU wine label regulations.
For more information:
- Step-by-step guide to QR code e-label upload
- Why use QR codes to comply with new EU regulations?
- In-house e-labeling: Avoid costly errors
- Data collection for winemakers: Mastering e-label upload
- New EU wine labeling: Compliance made simple
NOTE: Please be advised that the information presented in this article is not intended to provide legal advice or guarantee accuracy. You should always check the latest EU regulations to confirm the latest requirements and comply with applicable laws.