Effective from December 8, 2023, the European Union (EU) will introduce new labeling requirements for all wine sold within its member states. These regulations mandate the disclosure of specific information regarding ingredients, allergens, energy content, and nutritional details for wines that were not produced and labeled before the aforementioned date. Failure to comply with these requirements can result in penalties and the removal of non-compliant wines from the market. In this article, we will delve into the details of the new regulations and explore their implications for wineries.
The New Labeling Requirements
Following the December 8, 2023 deadline, all wines produced and labeled after that date must include information on ingredients, allergens, energy content, and nutrition. Allergens and intolerances should be clearly displayed on or physically attached to the product. Other information, such as ingredients, can be provided via electronic means, such as QR codes. Non-compliant wines must be taken off the market, and penalties may be imposed in accordance with the law.
Wines that were “produced and labeled” before December 8, 2023, are exempt from the new requirements and can continue to be sold in the EU until their supplies are exhausted. However, an official definition of “produced” has not been released yet. The wine industry currently interprets “produced” in the context of the law as “completed fermentation in the barrel.”
Wines that fail to adhere to the new regulations can be removed from the market, and administrative penalties can be imposed as per the new legislation. The responsibility for enforcement and inspections lies with each EU member state.
Other Alcoholic Beverages and De-Alcoholized Wine
It’s important to note that beer and spirits are not subject to these updated regulations. However, some spirits producers have voluntarily begun disclosing nutritional information via QR codes. Wines with lowered alcohol content or those that have undergone de-alcoholization processes are included in the same regulations as regular alcoholic wines, with some distinctions.
Wines containing alcohol content below 10% by volume, as well as those that have undergone de-alcoholization to achieve an alcohol content below 10%, are subject to the following regulations:
- – The minimum product durability, or expiration date, must be clearly indicated.
- – Wines with an alcohol content below 0.5% by volume should be labeled as “de-alcoholized.”
- – Wines with an alcohol content above 0.5% by volume should be labeled as “partially de-alcoholized.”
As of May 30, 2023, an updated regulation has been finalized. Starting from December 8, 2023, it is mandatory for wines with an alcohol content below 10% to include the declaration of the minimum product durability.
On-Bottle Labeling vs. Electronic Means
Wine labels must display energy information using the symbol “E,” indicating the calorie content per 100ml serving. Allergens and intolerances must be clearly printed on product labels, regardless of whether electronic labels are used. Ingredients and nutritional information can be made available through a QR code or URL on the label, directing consumers to a webpage with the required information. If electronic labels are used to disclose nutrition and ingredients, allergens and intolerances must also be included.
However, the latest regulation states that the following items, although mandatory, can be listed outside the field of vision:
- – Substances or products causing allergies or intolerances
- – Importer information
- – Lot number
- – Date of minimum durability
Even though these details are allowed outside the field of vision, they still need to be present on the label or attached to the wine bottle.
It’s important to note that the electronic label (e-label) must not include any sales or marketing content. Combining sales and marketing information with the mandatory ingredient or nutritional details would be a violation of the regulation.
Webpages and Compliance
Creating webpages on a wine brand’s website to provide information on each wine may not be compliant for several reasons. Many website platforms contain tracking software that could violate the law’s prohibition on storing customer data through e-labels. Furthermore, these webpages must not include any sales or marketing material, and they must be presented in an official EU language that is easily understood by consumers. To ensure compliance, employing specialized software solutions that generate clean webpages with only the required information is recommended.
The rules do not explicitly specify whether or how it is acceptable to provide a link to a wine producer’s website from a wine’s e-label without violating the requirements related to sales and marketing information or user data tracking.
Benefits of QR Codes
Many wineries are opting to use QR codes to comply with the new regulations due to several advantages:
- – Language Adaptation: QR codes can automatically be translated into the appropriate language based on the user’s location.
- – Real-time Updates: Labels can be modified in real-time, allowing for prompt rectification of any errors or issues that may arise after the labels are printed.
- – Flexibility: QR codes enable wineries to avoid significant changes to their physical labels while still providing different information to consumers based on their location. For example, EU consumers would see the compliant e-label, while American consumers would view marketing information. This requires the use of dynamic QR codes.
To learn more about this, please see Digital Solutions – EU Wine Labeling Legislation EU.
Key Takeaways for Wineries:
- – After December 8, 2023, all wine sold in the EU must provide allergy, energy, ingredient, and nutritional information on the labels if they were not produced and labeled before that date.
- – Allergy, intolerance, and energy information must be physically displayed on the wine label, while ingredient and nutrition details can be provided electronically through a QR code or web link.
- – QR codes offer benefits such as language adaptability, real-time updates, and flexibility, making compliance more manageable for wineries.
- – Compliance with the regulations is essential to avoid penalties and market removal of non-compliant wines.
- – It is crucial for wineries to familiarize themselves with these new labeling requirements and take the necessary steps to ensure compliance. By providing transparent and comprehensive information to consumers, wineries can demonstrate their commitment to product quality and consumer safety in line with the EU regulations.