Last updated: June 28th, 2024<\/strong><\/span><\/em><\/p>\n Any wine produced after December 8, 2023, and marketed in the EU is subject to the latest EU wine labelling requirements<\/p>\n This article summarizes the key points of the latest rules and provides answers to commonly asked questions that Scantrust<\/a> receives from winemakers.<\/p>\n Read this article if:<\/p>\n 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<\/a>.<\/p>\n<\/div>\n\n 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<\/a>.<\/p>\n 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.<\/p>\n 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<\/a> Chapter IV, Article 89.<\/p>\n<\/div>\n\n 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.<\/p>\n 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<\/a>.<\/p>\n<\/div>\n\n 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<\/a>, Article 90a<\/p>\n Enforcement with inspections is delegated to and will be handled by each E.U. member state.<\/p>\n<\/div>\n\n Energy information, similar to the declaration of calories in the U.S., must be displayed on wine labels using the symbol \u201cE\u201d based on a 100ml serving.<\/p>\n The following information must be displayed on the wine label itself:<\/strong><\/p>\n 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.<\/p>\n Note that the \u201celectronic 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.<\/p>\n 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<\/a>.<\/p>\n<\/div>\n\n 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.<\/p>\n<\/div>\n\n This approach is not complaint for several reasons.<\/p>\n 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)<\/a> for more information.<\/p>\n Furthermore, to be compliant, sales or marketing material shared in addition to the required details is prohibited.<\/p>\n 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.<\/p>\n Wineries or wine label service providers are obligated to serve “clean” webpages, including only information that is required.<\/p>\n<\/div>\n\n 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.<\/p>\n 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.<\/p>\n \u00a0<\/em><\/p>\n<\/div>\n\n Wineries are largely choosing QR codes to achieve E.U. wine label regulation compliance for these reasons:<\/p>\n\n
\n What are the new requirements?\n <\/h1>\n\n\n
\n What’s the deadline for compliance?\n <\/h1>\n\n\n
\n What happens if a wine is not compliant with the EU wine label rules?\n <\/h1>\n\n\n
\n What information is required to be shown on the wine label itself?\n <\/h1>\n\n\n
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\n What information can be provided by a URL or QR code?\n <\/h1>\n\n\n
\n What language must the information be displayed in?\n <\/h1>\n\n\n
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\n Is it compliant to create webpages with information on each wine on my wine brand’s website?\n <\/h1>\n\n\n
\n If I use a dedicated e-label solution, can I link to my own website?\n <\/h1>\n\n\n
\n What are the benefits of using QR codes to display the wine ingredient information?\n <\/h1>\n\n\n
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\n Do beer and spirits need to be compliant?\n <\/h1>\n\n\n