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
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- You\u2019re a wine producer selling wine in the European Union.<\/li>\n
- You\u2019re a wine distributor labelling wines for sale in the European Union.<\/li>\n
- You’re a label producer for wines sold in the European Union.<\/li>\n<\/ul>\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
\n What are the new requirements?\n <\/h1>\n\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
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
\n What’s the deadline for compliance?\n <\/h1>\n\n\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
\n What happens if a wine is not compliant with the EU wine label rules?\n <\/h1>\n\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
The following information must be displayed on the wine label itself:<\/strong><\/p>\n
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- Designation of category\u00a0<\/span><\/li>\n
- Intolerances and Allergens<\/li>\n
- Actual alcoholic strength by volume<\/li>\n
- Indication of provenance<\/li>\n
- Bottler; in the case of sparkling wine, the name of producer\/ vendor<\/li>\n
- Importer (in the case of imported wines)<\/li>\n
- Sugar content in the case of sparkling wine<\/li>\n
- Date of minimum durability for de-alcoholised wine products with an actual alcoholic strength by volume of less than 10%\u00a0<\/span><\/li>\n
- Lot number<\/li>\n
- Net quantity\u00a0<\/span><\/li>\n<\/ul>\n<\/div>\n\n
\n What information can be provided by a URL or QR code?\n <\/h1>\n\n\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
\n What language must the information be displayed in?\n <\/h1>\n\n\n
An example of a physical wine label with a QR code.<\/figcaption>\n <\/figure>\n\n \n Is it compliant to create webpages with information on each wine on my wine brand’s website?\n <\/h1>\n\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
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- They can automatically be translated into the right language, depending on where the user is scanning it.<\/li>\n
- You can change the labels in real-time, fixing any issues or errors you discover after you print the labels.<\/li>\n
- You can avoid large changes to your physical labels.<\/li>\n
- 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<\/a>.<\/li>\n<\/ul>\n<\/div>\n\n
\n Do beer and spirits need to be compliant?\n <\/h1>\n\n\n
Beer and spirits are not covered by this updated regulation. Despite that, some spirits producers such as Pernod Ricard have begun voluntarily disclosing<\/a> nutritional information via QR codes.<\/p>\n<\/div>\n\n
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- 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.<\/li>\n
- 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.<\/li>\n
- 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.<\/li>\n
- QR codes have several benefits, making compliance easier, more reliable, and less costly.<\/li>\n<\/ul>\n
For more information:<\/p>\n