If you are reading this, chances are you are a winemaker or work with wine or wine-based beverages. As wine lovers, we appreciate how much effort and passion it takes to maintain and improve a terroir, select and blend vines to perfection, age the vintages properly, and ensure maximum quality throughout the wine supply chain.
Well, now’s the time to furtherly highlight all this and more to connoisseurs and conscious consumers across Europe alike. Because from December 8, 2023, all wines and aromatized wines (like Vermouth, Quinquina, Lillet, or Americano) put on the market in the European Union must include a nutrition declaration and a list of ingredients on their labels.
These are the basic requirements introduced by the EU Regulation 2021/2117, putting into effect the European wine label reform – or should we say revolution?
At this point, you are most likely wondering how hard will this new law hit your business and what you should do to prepare and meet its obligations. We made sure to answer these questions and more with our guide to quickly learn the essentials of the new European wine label reform.
Ready? Let’s cut to the chase, then.
What is EU Regulation 2021/2117?
EU Regulation 2021/2117, published on December 2, 2021, integrates and amends previous regulations to enable the implementation of stricter requirements for wine and aromatized wine labels.
The ultimate purpose of this measure is to promote consumer health and food safety in the framework of the Common Agricultural Policy (CAP) program and the so-called European “Farm to Fork” strategy.
High-level objectives apart, the key takeaway here for winemakers and distributors is that all bottles sold within the EU borders will have to provide consumers with a nutrition declaration and a detailed list of ingredients.
This information can be printed directly on the label or made available “by electronic means,” except for the energy value (with the symbol “E”), which must always be shown on the label, as well as any substance that might cause allergies or intolerances.
But what does “by electronic means” exactly mean? Simply put, you can redirect buyers through a digital link QR code to an online resource where all the mandatory info is available. Without cluttering the label too much, and free to edit data whenever necessary – no need to reprint any labels.
Remember, though, that the page hosting the mandatory info should avoid collecting or tracking user data and should not provide content aimed at marketing purposes.
In addition, as stated by article 15 of EU Regulation 1169/2011, mandatory information must be provided in a language easily understood by the consumers of the EU country where a food or beverage is marketed.
What is a nutrition declaration for wines?
According to EU law, a compliant nutrition declaration must inform consumers about a food or beverage’s energy and nutrient content. The minimum mandatory information required is:
- energy value
- amounts of fat, saturates, carbohydrates, sugars, protein, and salt
In addition to that, optional information includes amounts of:
- mono-unsaturates
- polyunsaturates
- polyols
- starch
- fiber
- any of the vitamins or minerals permitted by law
The values displayed in the nutrition declaration are averages. They can be based on analysis made by the manufacturer, calculated using the known or actual average values of the ingredients, or with generally established and accepted data.
The energy value must be indicated in kilojoules (kJ) and kilo calories (kcal) per 100 g or 100 ml, and nutrient amounts must be indicated per 100 g or 100 ml. Anyway, article 33 of EU Regulation 1169/2011 lists a few cases in which values expressed per portion or consumption unit (for instance, “a glass”) can be added to the information per 100 g or 100 ml, or replace it entirely.
What’s especially important is that the most accepted way of displaying the nutrition declaration is in table form.
What is a list of ingredients for wines?
A general rule for ingredient lists in the EU is that all lists must be preceded by a heading including the word “ingredients” and must include all the ingredients in descending order of weight, each one designated by its specific name.
Details about how ingredients should be displayed on food and beverage labels are provided by Annex I to XV of EU Regulation 1169/2011.
Not keen on reading an entire regulation of the European Parliament and of the Council? We’ve got you covered. Here is a list of wine ingredients that could be included in the new labels:
- grapes
- grape must
- saccharose
- concentrated/rectified grape must
- liqueur d’expedition
- stabilizers and acidity regulators such as tartaric acid, metatartaric acid, malic acid, lactic acid, fumaric acid, citric acid, calcium sulfate, gum arabic, yeast mannoproteins, carboxymethylcellulose (CMC), and potassium poly aspartate (these can be preceded by “May contain”)
- preservatives and antioxidants such as sulfur dioxide, potassium bisulfite, potassium metabisulfite, potassium sorbate, lysozyme, ascorbic acid, and dimethyl dicarbonate (DMDC)
- gas preservers such as argon, nitrogen, and carbon dioxide (these can be included by simply writing “Bottled in a protective atmosphere”)
- other substances such as Aleppo pine resin and caramel.
We’re keeping this list updated as further details are released from the authorities.
What is the deadline to comply with the wine label requirements introduced by EU Regulation 2021/2117?
The regulation provided a 2-year transition period, so any wine and aromatized wine produced and labeled after December 8, 2023, must meet its requirements.
Wines and aromatized wines produced and labeled before December 8, 2023, can still be marketed in the EU until stocks last. Relabeling bottles already on the market is not required.
What are the consequences for not complying with the new wine label reform?
EU Regulation 2021/2117 doesn’t explicitly establish penalties or fines for non-compliant products, leaving it to the Member States to take adequate measures to:
- ensure that wines and aromatized wines not labeled in conformity with the regulation are not placed on the market and, if they are already available, are withdrawn from the market
- apply effective penalties for non-compliant producers and distributors
We will provide more details about fines and penalties as soon as Member States release them.
Is the wine label reform limited to the European Union?
EU Regulation 2021/2117 is a European law and only affects EU countries – which, by the way, represent 63% of global wine production and 57% of global wine consumption, plus 70% of total wine exports.
But it’s very likely that similar requirements might be introduced soon in other countries, like the U.S.
The U.S. Treasury Department released the report “Competition in the Markets for Beer, Wine, and Spirits” in February 2022, responding to a direct order from President Biden.
The report advises the Alcohol and Tobacco Tax and Trade Bureau (TTB), which regulates alcoholic beverages in the U.S., to implement “regulatory proposals that could serve public health and foster competition by providing information to consumers, such as mandatory allergen, nutrition, and ingredient labeling.”
So, more robust label regulations are expected in the country that ranks fourth among wine producers worldwide, after Italy, France, and Spain. And more will follow.
How to comply with the wine label reform requirements of EU Regulation 2021/2117?
The easiest and most flexible solution to meet the new requirements for wine and aromatized wine labels in the EU is to use digital link QR codes to connect consumers to the mandatory info.
Digital link QRs, like the ones we provide, encode a web address combined with the GTIN information.
This way, the same QR code can be used at points of sale for checkout, while consumers who read it with their smartphones are redirected to a product page displaying the nutrition declaration and the list of ingredients, plus links to all relevant online resources like recipes, interactive winery tours, educational videos, loyalty programs, e-shops: the sky’s the limit.
Not to mention that with a digital link QR code, you can get rid of all other barcodes and marketing QRs on labels in a single move.
In a nutshell:
- digital link QR codes help companies comply with the EU wine label regulations and any other present or future legal requirements for wine packaging
- digital link QR codes free up space on labels by combining all the functionalities of other barcodes, QRs, Data Matrix, and tags currently printed or attached to bottles
- digital link QR codes streamline processes across the whole supply chain
- digital link QR codes provide new ways to establish and maintain brand-consumer relationships, improving the customer experience.
Since the 2027 deadline for the global transition from the old barcodes to digital link QR codes is quickly approaching, it’s a win-win!
Eager to discover more and get ready for the wine label revolution? Get in touch with our experts at info@digital-link.com
We will be more than happy to answer all your questions and design a solution tailored to your needs.
