EU changes to wine labelling

8 December 2023 is not only the Feast of the Conception of Mary and a public holiday in the wine exporting country of Italy, but also the date on which important changes to the labelling of wines, sparkling wines, fruit wines and aromatised wines come into force. Under Regulation (EU) 2021/2117, all such wines sold in the EU from this date onwards must be labelled with new information as part of a revision of the EU's Common Agricultural Policy.

Until now, mandatory labelling information only concerned allergens (eg sulphites), alcohol content, bottler etc. Now, wine producers (like food producers) must also list nutrition values (eg energy, fat, carbohydrates, sugar, protein and salt content per 100 ml or per portion), as well as ingredients (including the percentage of each ingredient in descending order) on wine labels. Allergens must be indicated in the list of ingredients and must be clearly emphasised, such as by using a different font or font style (eg bold type).

In order to provide consumers with comprehensive information when shopping and to promote transparency between producers in the EU wine industry, this information must be provided on the wine bottle or on a label affixed directly to the product packaging. When it comes to nutrition values, the content of the physical labels on the wine bottle can be limited to a nutrition declaration of the energy value of the product (roughly comparable to a declaration of "calories" in the US). The full nutrition declaration can be provided electronically on the label (such as via an e-label, QR code or URL), as can the list of ingredients.

This electronic solution offers several advantages: it saves space on the wine label, the information can be provided in different languages, and it can be corrected or adapted at short notice. All information provided electronically must be correct, up-to-date and easily accessible to the consumer.

The following must also be observed:

• Calorific value information ("kJ", "kcal") and allergen labelling (eg "contains sulphites") (where applicable) if provided under the QR code must be indicated also on the "physical" wine label.
• Information intended for sales and advertising purposes (eg links to an online shop) may not be included on electronic labels. Therefore, electronic labels must not link to the wine producer's website or app, but must be hosted on an independent platform that does not contain any marketing or sales information and does not allow user tracking.
• No user data can be collected or tracked electronically. This is because the use of electronic means must not prevent the consumer from making informed purchasing decisions or accessing the necessary information.

The legal changes not only affect offline wine labelling, but also the presentation of wines in online shops and in price lists.

Failure to comply with these labelling requirements can result in costly competition law warnings and lead to a wine producer's products being withdrawn from the market.

The changes come at the time of proposals to change retained UK law on wines (see here and here).