Last updated: December 11, 2023

Any wine produced in the E.U. after December 8, 2023 or imported after that date is subject to the latest E.U. wine labelling requirements.

This article summarizes the key points of the latest rules and provides answers to commonly asked questions that Scantrust receives from winemakers.

Read this article if:

• You’re a wine producer selling wine in the European Union.
• You’re a wine distributor labelling wines for sale in the European Union.
• You’re a label producer for wines sold in the European Union.

If you are already familiar with the law and are looking for step-by-step information on how to comply, visit our guide on how to use QR codes and e-labels for compliance.

All wine that falls within applicability based on production and import date must include disclosure of ingredients, allergen, energy, and nutrition information, in accordance with Regulation (EU) 2021/2117.

Allergens and intolerances must appear on or be physically attached to the product while ingredients and nutrition details can optionally be disclosed via “electronic means” such as with a QR code.

Wine which is not in compliance will be removed from the market and may have penalties applied as well, according to the law, and with enforcement happening at the individual member state level. Details can be reviewed in Regulation (EU) 1306/2013 Chapter IV, Article 89.

Wine which was “produced” in the E.U. before December 8, 2023, or imported before that date, is exempt from the requirements and can continue to be sold in the E.U. after that date, until the exhaustion of supplies. All wines outside of those exceptions must be in compliance.

The definition of “produced” varies according to the type of wine. Although some wines require a second fermentation and increase CO2 content during that additional process, it is not an exception and “produced” applies only after the second phase of processing. This was clarified most recently in a November 24, 2023 commission notice update.

Wine that fails to comply with the new regulations can be removed from the market and incur administrative penalties in accordance with regulation Regulation (EU) 1308/2013, Article 90a

Enforcement with inspections is delegated to and will be handled by each E.U. member state.

Energy information, similar to the declaration of calories in the U.S., must be displayed on wine labels using the symbol “E” based on a 100ml serving.

The following information must be displayed on the wine label itself:

• Designation of category 
• Intolerances and Allergens
• Actual alcoholic strength by volume
• Indication of provenance
• Bottler; in the case of sparkling wine, the name of producer/ vendor
• Importer (in the case of imported wines)
• Sugar content in the case of sparkling wine
• Date of minimum durability for de-alcoholised wine products with an actual alcoholic strength by volume of less than 10% 
• Lot number
• Net quantity 

Ingredient and nutritional information must be provided, but these can be made available through a QR code or URL on the wine label which sends the consumer to a webpage with that information.

Note that the “electronic label” or e-label cannot contain any information intended for sales or marketing purposes. Distributing sales and marketing details alongside the required ingredient or nutritional details is a violation of the regulation.

For more detail on how to disclose the nutrition and energy information, such as how to calculate the energy values and how to organize allergens according to the rules, see this detailed guide.

The law requires making the above information available in an official E.U. language easily understood by the consumer. It further states that E.U. member countries can specify the languages which e-labels must be displayed in.

This approach is not complaint for several reasons.

Most platforms used to build websites contain tracking software which could store data about customers who view your e-labels. This is explicitly forbidden by the law – see 2021/2117, Article 16a (32) (c) for more information.

Furthermore, to be compliant, sales or marketing material shared in addition to the required details is prohibited.

Lastly, the content would have to appear in one or more official E.U. language which is easily understood by the consumer to be compliant.

Wineries or wine label service providers are obligated to serve “clean” webpages, including only information that is required.

When a wine producer uses software to generate QR codes and e-labels for their wines, it’s not surprising that they may want to include links in the mandatory details “e-label” so that customers can easily find the wine brand’s official website.

Unfortunately, the most current rules clearly specify that mandatory information must not be served alongside any sales or marketing information or content. Additionally, gathering user data that is personally identifying is also prohibited.

Wineries are largely choosing QR codes to achieve E.U. wine label regulation compliance for these reasons:

• They can automatically be translated into the right language, depending on where the user is scanning it.
• You can change the labels in real-time, fixing any issues or errors you discover after you print the labels.
• You can avoid large changes to your physical labels.
• You can provide different information to consumers depending on where they are located when they scan the wine bottle; for example, an E.U. consumer would see the compliant e-label, while an American one could see relevant marketing information or their own regulatory environment details. This type of feature is made possible by the use of Dynamic QR codes.

Beer and spirits are not covered by this updated regulation. Despite that, some spirits producers such as Pernod Ricard have begun voluntarily disclosing nutritional information via QR codes.

Wines that have had their alcoholic content lowered or “de-alcoholized” through a process are included in the same regulations as for normal, alcoholic wines, though there are some distinctions depending on the amount of alcohol included in the beverage.

The term “de-alcoholised” (U.K. spelling) must be included, and can be provided digitally if the alcohol by volume is no more than .5%. The term “partially de-alcoholised” can be used if the alcohol by volume is more than 0.5% but below the minimum actual alcoholic strength of the category before de-alcoholisation. One important distinction is that for any wines with strength by volume of less than 10 %, the date of minimum durability is necessary to be included on the physical label, and may additionally be provided through electronic means.

In summary:

• All wine sold in the European Union which not produced or imported before December 8, 2023, will be legally required to provide allergy, energy, ingredient and nutritional information to consumers on their labels.
• Intolerance, allergy, and energy information must be printed directly on the physical wine label. Ingredient and nutrition information can be provided electronically via a QR code or a web link.
• The QR code or web link cannot ambiguously direct the consumer to a webpage with marketing or sales information. Collection of personally identifiable information is also strictly prohibited: there are no exceptions.
• QR codes have several benefits, making compliance easier, more reliable, and less costly.

For more information:

• How to use QR codes to comply with new E.U. wine label rules
• Summary of draft law updating E.U. wine label requirements

*List of potential allergens that MUST be included on the printed bottle label if present in the product:

List of intolerances and allergens. (1); (a) Cereals containing gluten, namely: wheat, rye, barley, oats, spelt, kamut or their hybridised strains, and products thereof, except: (a) wheat based glucose syrups including dextrose (1); (b) wheat based maltodextrins (1); (c) glucose syrups based on barley; (d) cereals used for making alcoholic distillates including ethyl alcohol of agricultural origin; 2. Crustaceans and products thereof; 3. Eggs and products thereof; 4. Fish and products thereof, except: (a) fish gelatine used as carrier for vitamin or carotenoid preparations; (b) fish gelatine or Isinglass used as fining agent in beer and wine; 5. Peanuts and products thereof; 6. 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; 7. Milk and products thereof (including lactose), except: (a) whey used for making alcoholic distillates including ethyl alcohol of agricultural origin; (b) lactitol; 8. 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; 9. Celery and products thereof; 10.Mustard and products thereof; 11. Sesame seeds and products thereof; 12. Sulphur dioxide and sulphites at concentrations of more than 10 mg/kg or 10 mg/litre 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; 13. Lupin and products thereof; 14. Molluscs and products thereof.

NB! No legal advice or guarantee of accuracy is offered in this article. Always check the latest E.U. regulations or other government regulation details with original sources.