A guide to the new EU wine labelling regulations

A guide to the new EU wine labelling regulations

The European Union has implemented changes to its Common Agricultural Policy (CAP) that will affect wine labelling requirements for wines intended for sale and consumption within the E.U. As of December 8th, 2023, all wine bottles labelled from the deadline and sold within the European Union, regardless of origin, must include new information, as specified in regulation (EU) 2021/2117 of the European Parliament and the Council. The new regulations aim to provide consumers with more information about the wine they are purchasing and consuming.

The following is a concise compilation of key information extracted from current legal provisions. However, it is important to note that this collection does not constitute legal advice and may be subject to updates.

The new EU wine labelling regulations

The new labeling regulations require that wine labels display the following information in full text:

• A nutrition declaration
• A list of ingredients
• Any potential allergens, listed under the word “Contains”

In addition, wine labels must display energy information, similar to the declaration of calories in the U.S., using the symbol “E”.

Allergens and intolerances, as well as the energy information, must appear on the physical label on the bottle. While, Nutritional declaration and list of ingredients can be disclosed via "electronic means".

^{Producers should have the option of limiting the contents of the nutrition declaration on the package or on a label attached thereto to only the energy value and of making the full nutrition declaration and the list of ingredients available by electronic means, provided that they avoid any collection or tracking of user data and do not provide information aimed at marketing purposes. However, the option of not providing a full nutritional declaration on the package or on a label attached thereto should not affect the existing requirement that the label list substances causing allergies or intolerances.
E.U. Regulation 2021/2117}

Compliance through electronic means such as QR code

It is important to note that if nutrition declarations and lists of ingredients are made available by electronic means, producers must:

• Avoid collecting or tracking user data
• Avoid providing information intended for sales or marketing purposes through electronic labels
• Provide an e-label in one or more languages that are easily understandable by consumers in the EU.

^{[...] the nutrition declaration on the package or on a label attached thereto may be limited to the energy value [...]. In such cases, the full nutrition declaration shall be provided by electronic means identified on the package or on a label attached thereto. That nutrition declaration shall not be displayed with other information intended for sales or marketing purposes and no user data shall be collected or tracked.
Regulation 2021/2117}