Many winemakers who sell wine in Europe have been busy preparing their compliance with Regulation (EU) 2021\/2117<\/a> and several other regulations related to wine labelling. The most obvious change with the current Regulation E.U. 2021\/2117 is the requirement to provide ingredient, nutrition, energy, and allergen information along with wines sold in the E.U. starting December 8, 2023.<\/p>\n An update to the laws, 2023\/3257<\/a>, was published on May 30, 2023. Notable changes include:<\/p>\n An additional set of clarifications were released on November 24, 2023. You can read a summary of those clarifications here from the “Questions and answers on the implementation of new EU wine labelling provisions following the amendment of Regulation (EU) No 1308\/2013 of the European Parliament and of the Council and Commission Delegated Regulation (EU) 2019\/33”<\/a>. Read onward for more information about the earlier changes and still relevant information from Regulation E.U. 2023\/3257.<\/p>\n<\/div>\n\n Winemakers frequently use different additives in different batches of the same wine, often late in the process after labels have already been printed and applied.<\/p>\n Considering this, the new regulation takes a sympathetic stance regarding listing of ingredients and additives, a complete list of which can be found in article 48a of Regulation (EU)2019\/33. Because it is impractical to track and disclose each and every additive used in each and every bottle of wine, the new regulation requires that the ingredient list for a product include an exhaustive list of additives that could potentially be used in the winemaking process.<\/p>\n Put another way, it’s acceptable from the perspective of the law that additives listed on a label may not be actually present in the wine of that bottle.<\/p>\n Among the sub-category of additives \u2018acidity regulators\u2019 and \u2018stabilising agents\u2019, requirements are more specific. Regulators and stabilizers need to be listed using the expression \u201ccontains\u2026 and\/or\u201d, followed by no more than three additives. At least one of those additives listed is expected to be present in the final product.<\/p>\n Among the sub-category \u2018packaging gases\u2019, such as carbon dioxide, argon, and nitrogen which do not become a part of the product consumed, these may be omitted from the ingredient list if the producer uses either of the following statements:<\/p>\n Allergens and intolerances are required to be printed on the product label regardless of whether you are using electronic labels or not. If you’re using an electronic label to disclose nutrition and ingredients, allergens and intolerances must be included there as well.<\/p>\n The original regulation (2019\/33)<\/a> provides guidance on where these compulsory particulars are expected on wine sold in the E.U. The \u201cfield of vision\u201d is a simple but important concept in this matter and it is explained in Regulation EU 2019\/33<\/a> as anything that is legible without the need to turn the package or bottle. This latest regulation states that the following items, while compulsory, can be listed outside the field of vision:<\/p>\n It\u2019s important to understand that while these are allowed outside the field of vision, they are still required on the label or attached to the wine bottle.<\/p>\n<\/div>\n\n\n
\n Clarification on how to disclose additives regardless of variations from one bottle to another\n <\/h2>\n\n\n
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\n Field of vision: an update on where allergens and intolerances can be displayed\n <\/h3>\n\n\n
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