EU Regulation 2021/2117, adopted in December 2021 as part of the Common Agricultural Policy (CAP) reform, introduced mandatory ingredient and nutritional labelling for wine for the first time. Since 8 December 2023, all wines produced and sold within the European Union — regardless of origin — must declare allergens, ingredients, and nutritional information on their labels.
This article explains what the regulation requires, what changed with the 2026 update, and what happens if you don't comply. For a comprehensive, section-by-section deep dive into every compliance detail, see our Wine E-Label Masterguide.
This guide summarises EU wine labelling requirements for informational purposes. For legal advice specific to your situation, consult a qualified wine law professional. Last updated: March 2026.
What Changed: EU Regulation 2021/2117
Before December 2023, wine was one of the few food products exempt from ingredient and nutritional labelling requirements. Regulation 2021/2117 ended that exemption by amending the Common Market Organisation regulation (EU No 1308/2013), requiring producers to provide:
- A full ingredient list, headed with the word "Ingredients," with grapes listed first
- A complete nutritional declaration (energy, fat, saturated fat, carbohydrates, sugars, protein, salt per 100 ml)
- Allergen declarations for substances like sulphites, egg-derived, and milk-derived products, listed under the word "Contains"
The regulation applies to all wines placed on the EU market after 8 December 2023, including imports from third countries. There are no exemptions based on producer size — small, family-run wineries face the same requirements as large cooperatives.
The implementing framework consists of three key instruments alongside the main regulation:
| Instrument | Role |
|---|---|
| Regulation (EU) 2021/2117 | Primary amendment requiring ingredients and nutritional declarations |
| Commission Delegated Regulation (EU) 2023/1606 | Supplementing rules for ingredient lists, e-labels, and presentation |
| Commission Implementing Regulation (EU) 2023/1607 | Technical implementation rules |
| Commission Notice C/2023/1190 | Official Q&A guidance (40 answers) published 24 November 2023 |
What Must Appear on the Physical Label vs the E-Label
The regulation distinguishes between information that must be printed on the physical bottle label and information that may be provided electronically via a QR code. This distinction is what makes e-labels possible — and necessary.
| Information | Physical label | E-label (via QR) |
|---|---|---|
| Allergens (sulphites, egg, milk) | Required | Optional (duplicate) |
| Energy value (kJ/kcal per 100 ml) | Required | Optional (duplicate) |
| Full nutritional declaration | Optional | Required if not on physical label |
| Complete ingredient list | Optional | Required if not on physical label |
| Product category | Required | — |
| Alcohol content | Required | — |
| Provenance | Required | — |
| Bottler/producer name and address | Required | — |
| Net content | Required | — |
| Lot number | Required | — |
| Sugar content (sparkling wines) | Required | — |
The energy value must be displayed using the "E" symbol with a minimum font height of 1.2 mm. Allergens must be visually highlighted — bold text is the recommended approach.
For full details on each element, including ingredient ordering rules, nutritional calculation methods, and allergen thresholds, see the ingredient list requirements and nutritional declaration sections of our masterguide.
E-Label Rules: What Your QR Code Page Must (and Must Not) Include
If you use a QR code to provide the ingredient list and nutritional declaration electronically, the landing page must meet strict requirements:
Required: The page must display factual, mandatory information only — ingredients, nutrition, and allergens — in a language easily understood by the consumer. It must be mobile-responsive, load directly (no intermediate pages or login screens), and include appropriate GDPR-compliant legal notices.
Prohibited: Any marketing content, sales links, tasting notes, awards, social media links, or purchase functionality. The regulation also strictly prohibits cookies, tracking pixels, analytics tools (including Google Analytics), and any form of user data collection on e-label pages.
The EU regulation does not prescribe a specific minimum QR code size — the key requirement is that it must be readable by any standard smartphone camera. In practice, we recommend a size between 1.2 cm × 1.2 cm and 1.5 cm × 1.5 cm, with 1.5 cm being required for the Italian market and ideal for all markets. The QR code must be accompanied by a heading that contains the word "Ingredients" — the "i" symbol alone is not sufficient, as clarified in Commission Notice C/2023/1190. The code must be clearly visible, not obscured by other design elements, and printed at 300 DPI or higher for reliable scanning.
For the complete list of landing page restrictions and QR code specifications, see the landing page rules and QR code requirements sections of our masterguide.
Sparkling Wine: Additional Sugar Content Requirements
Sparkling wines must declare their sugar content category on the physical label. This is not required for still wines. The EU-defined categories are:
| Category | Sugar content |
|---|---|
| Brut nature / Pas dosé | Less than 3 g/L |
| Extra brut | Up to 6 g/L |
| Brut | Less than 12 g/L |
| Extra dry | 12–17 g/L |
| Dry (Sec) | 17–32 g/L |
| Demi-sec | 32–50 g/L |
| Doux (Sweet) | More than 50 g/L |
Sparkling wines also have a different definition of "produced" for transition purposes — they are considered produced only after the second fermentation is complete and the required alcohol content and overpressure have been achieved.
2026 Update: What Changed with Regulation 2026/471
In February 2026, the EU Council adopted Regulation 2026/471, which became enforceable on 18 March 2026. While the core e-label obligations from 2021/2117 remain unchanged, the new regulation introduces several important updates:
Export exemption. Wines produced exclusively for export outside the EU are now exempt from the ingredient and nutrition declaration requirements. This is a significant relief for producers who sell to non-EU markets such as the United States, the United Kingdom, or China and previously had to comply even for wines that would never be sold to EU consumers.
Dealcoholized wine terminology. The regulation introduces harmonised definitions: wines with less than 0.5% ABV must be labelled "dealcoholized," while those between 0.5% and the minimum category strength are "partially dealcoholized." This replaces the patchwork of national terms that previously caused confusion across markets.
Labelling simplification. Additional measures simplify labelling rules and expand planting flexibility, aiming to reduce the administrative burden on producers while maintaining consumer transparency.
The regulatory landscape for wine labelling continues to evolve. QRFox.eu E-Labels is developed in collaboration with legal experts and enologists who monitor regulatory changes and proactively update the platform, so producers don't need to track amendments in the Official Journal themselves.
Transition Rules: Which Wines Are Exempt?
Wines produced or bottled before 8 December 2023 are exempt from the new labelling requirements and may continue to be sold with their existing labels until stocks are exhausted. There is no obligation to relabel older vintages.
The definition of "produced" varies by wine type:
- Still wines are considered produced when they meet legal requirements (prescribed alcohol content, acidity) and are recorded in the telematic wine register. In practice, wines from the 2024 harvest onwards must fully comply.
- Sparkling wines are considered produced only after the second fermentation is complete and the specific alcohol content and overpressure conditions are achieved. This was clarified in the Commission's Q&A document (C/2023/1190), published on 24 November 2023 — just two weeks before the compliance deadline, which caused significant concern across the industry.
- Imported wines produced before 8 December 2023 are treated the same as domestic wines and remain exempt until stocks are exhausted.
Penalties for Non-Compliance
Enforcement is administered by the competent authorities in each EU member state, so penalties vary by country. Under Regulation (EU) 1308/2013, Article 90a, non-compliant wines may be removed from the market.
Italy: The primary enforcement body is the ICQRF (Ispettorato Centrale della Tutela della Qualità e della Repressione Frodi). Under Legge 238/2016, Article 74, wine labelling violations carry administrative fines of EUR 250 to EUR 5,000 per infringement, with potential sales stops on non-compliant batches and product recalls in severe cases. Italy also requires compliance with environmental labelling under D.Lgs. 116/2020, where separate penalties apply.
France: The DGCCRF (Direction Générale de la Concurrence, de la Consommation et de la Répression des Fraudes) enforces labelling compliance. Fines range from EUR 3,000 to EUR 300,000, and the DGCCRF can impose daily penalties of up to EUR 3,000 for continued non-compliance. Recent DGCCRF inspections across the food and beverage sector have found significant rates of labelling non-compliance.
Other EU member states enforce under their respective national legislation. Germany enforces through state-level food safety authorities under the Weingesetz (Wine Act) and general food law (LFGB), while Spain's enforcement falls under autonomous community authorities. Specific fine ranges vary — consult local legal counsel for the exact penalties applicable in your market.
Beyond direct fines, non-compliance carries reputational risk and can result in products being pulled from retail shelves, disrupting distribution relationships.
What to Do Now: Getting Compliant
If you haven't yet updated your labels, here is a practical checklist:
- Audit your current labels — identify which wines produced from December 2023 onwards are missing ingredient, nutritional, or allergen information
- Gather your wine data — you'll need lab analysis reports, a record of all additives used, and allergen information for each wine
- Choose an e-label provider — look for a platform that handles automatic translation across EU languages, provides a pre-translated ingredients and allergens database, and hosts compliant, cookie-free landing pages. For guidance, see our article on how to choose an e-label provider.
- Create your e-labels — enter your wine data, review the generated declarations, and verify translations for your target markets
- Generate and print QR codes — download print-ready files (SVG or PDF at 300+ DPI) and share with your label printer
- Test before shipping — scan the QR code from a smartphone, verify it loads the correct information in the right language, and confirm there is no marketing content or tracking on the page
For a detailed step-by-step walkthrough with screenshots, see the How to Create an E-Label section of our masterguide.
Ready to get started? Create your first compliant e-label free — no credit card required. If you have questions, get in touch with our team.
