EU wine nutrition label requirements from 8 December 2023: Guide for wineries.
What does the legislation provide for the electronic nutrition label: According to the European regulation (EU) 2021/2117, in order to provide a higher level of information to consumers, the mandatory particulars under Article 119 of Regulation (EU) No 1308/2013 should include
- nutrition declaration and
- list of ingredients.
However, producers should have the option to limit the contents of the nutrition declaration on the packaging or on a label attached to it to the energy value only and to make the full nutrition declaration and the list of ingredients available electronically, provided that they avoid the collection or monitoring of user data and do not provide information for the purpose of commercial promotion. However, the option not to provide a full nutrition declaration on the packaging or on a label attached to it should not affect the existing requirement for the label to indicate substances causing allergies or intolerances.
Denial of responsibility
This document is an interpretation of current law and a compilation of reliable legal opinions regarding nutrition and ingredient labeling for wine. Please consult a legal professional for the most up-to-date information. This information is also subject to change.
Table of Contents
- Requirements for mandatory indications on electronic labels
- Information on the use of electronic labels (QR codes)
- Translation capability
- Label lifespan
- Ensuring privacy
- Sales – marketing
- File downloads
- No navigation
- What if I just put the information on my website?
- Advantages of QR codes (electronic labels)
- Get started with electronic labels
- List of ingredients
- Nutritional declaration
- Packaging information
- Natural wine label
- The QR code.
What are the requirements for mandatory indications on electronic labels?
For any wine sold in the EU, it must be provided:
- List of ingredients
- Nutritional information
Attention: If wines can be ordered directly by the end consumer in a price list, brochure, online store, etc. (e.g. via e-shop, by phone, in writing, by e-mail), the list of ingredients and nutritional information must also be provided at the time of purchase.
The regulation applies to wines produced after 8 December 2023 for sale in the EU.
All wines with a vintage of 2024 and later must comply.
Information on the use of electronic labels (QR codes)
The full list of ingredients on the nutrition label may be available via an electronic label – a QR code on the printed label that links to a mobile website.
According to the regulation, there are certain conditions that electronic labels must meet.
Translation capability.
Labels should be able to be translated into the languages of any country you may sell your products in using official EU translations.
Label lifespan
Your electronic labels must remain available for as long as the wine is expected to remain fit for consumption under normal storage. The presence and accuracy of the information is the responsibility of the business operator responsible for food information, in accordance with Article 8(2) of the FIC Regulation.
Ensuring privacy
No user data collection is allowed. This means no tools like Google Analytics – Link to wine-elabels.eu Privacy Compliance Report
Sales – marketing
Electronic labels are not allowed to display other information related to the sales and marketing of the product.
File downloads
There should be no PDF or other file downloads for the consumer to access the content of the e-label
No navigation
The user does not have to click to go to another page with the information except for the language selection.
What if I just put the information on my website?
It is allowed, however you just need to meet all the above requirements. For most producers, it is not feasible and/or more expensive than using a third-party solution, as it will require creating a separate website infrastructure from your marketing website and online store.
Advantages of QR codes (electronic labels)
QR codes have many advantages:
- First, the QR code offers a space-saving solution without compromising the label design.
- Secondly, QR codes are dynamic, meaning that the information behind the QR code can be updated at any time. This is particularly important, as it is common for the final data of the bottled wine to often not be available when the labels are printed. Thanks to dynamic QR codes, however, this data can be added at the time the product is released to the market.
- Thirdly, QR codes also allow for easy integration into online stores in price lists or brochures.
Get started with electronic labels
You can create 3 free e-labels today (no commitment or credit card required)
Follow the link below to create 3 free e-labels (no commitment or credit card required).
Select free registration to enter the platform and then select the use of the free service "FREE"
Through this process you will be guided through the creation of a compatible electronic label.
There are seven main sections that you will complete to create the electronic label. Not all of them are mandatory. You can fill in only the mandatory elements imposed by the specific regulation or expand on additional information such as technical characteristics, sustainability information, packaging, recycling instructions (which are necessary for certain markets), commercial representative, etc.
It is recommended that you create a new electronic label for each:
- new product
- different volume product
- new crop product
Caution: once an e-label is released on the market, it should not be updated unless the information needs to be corrected. For example, do not use the same e-label for the new vintage by simply updating the information on the label of the previous vintage. This will result in non-compliance with the label of the older vintage.
List of ingredients
We use official EU ingredients in our ingredient selector. The platform will format your list to comply with the legislation. For example, you will see intensively allergens to differentiate them from the rest of the ingredients text
When choosing ingredients, there are a few rules to keep in mind.
Regarding the presentation of the catalog:
- The list of ingredients is preceded by a heading containing the word "ingredients".
- The list shall list the ingredients in descending order of content by weight, as recorded at the time of their use in the preparation of the food. Ingredients used in a proportion of less than 2 % in the final product may be listed in a different order after the other ingredients.
- Ingredients are listed by their specific name, with the exceptions provided for in the FIC Regulation and Delegated Regulation (EU) 2019/33 (e.g. “grapes” listed as a raw material).
- The identification of additives in the list of ingredients must be done by the name of their functional category, followed by their specific name or, as the case may be, by the E number.
- Article 48a(5) of Delegated Regulation (EU) 2019/33 provides for the possibility of indicating additives belonging to the categories "acidity regulators" and "stabilizers" (which are similar) may be substituted for each other by using the expression "contains... and/or", followed by a maximum of three additives, when at least one of them is contained in the final product.
- It is mandatory to list any ingredient or technological aid (processing aid) that causes allergies or intolerances and is used in the production of the product and is still present in the final product, even in a modified form.
- If several wines are blended, it is recommended to list all ingredients used in total (e.g. tartaric acid or sulfur dioxide only once in the list).
- Ingredients must be listed in descending order of weight as used in the preparation of the food. Ingredients that constitute less than 2% of the final product may be listed in any order, after the other ingredients.
- Some additives used as packaging gases (carbon dioxide, argon and nitrogen) have the main purpose of displacing oxygen during bottling of wine products but do not become part of the product consumed. In these cases, you may choose to add “Bottled in a protective atmosphere” or “Bottling may be done in a protective atmosphere”.
Nutritional declaration
You can use the energy calculator we provide you through the platform or manually enter your own data.
To calculate the energy, it is necessary to fill in some data such as the alcohol percentage, residual sugars, total acidity and glycerin. The calculation is based on the official energy conversion factors of the European regulation.
For wines with a sugar content below 100 g/l (usually all wines except sweet wines), a tolerance of 2 g/100 ml (equivalent to 20 g/l) is allowed for the sugar/carbohydrate declaration.
Fat, saturated fat, protein and salt are contained in almost all wines only in negligible quantities, as long as good production practices are followed.
You have three options for negligible amounts of fat, saturated fat, protein and salt. You can enter “0” as a value, you can select the statement “contains negligible amounts” or you can choose to display a simplified table for negligible amounts (fat, protein, salt).
More information on negligible amounts can be found in section 6, table 4 of the EU guidance documents on nutrition labelling for EU 1169/2011.
You are responsible for declaring prices that exceed these tolerances, however many associations and legal experts state that for standard wines, additional testing is not required.
Packaging information
In Italy you are required to indicate the material recycling code on your packaging and provide waste collection instructions in accordance with the Legislative Decree of 3 April 2006, n. 152.
This can be done entirely through the electronic label by searching and selecting the materials you use.
Natural wine label
You will need to add three elements to your back label:
- The energy in kj and kcal in the form: 100 mL: E= XXX kJ/ XXX kcal. It is important not to use capital letters when writing kJ and kcal.
- The presentation of a QR code should be clear to consumers as to its content, i.e. the mandatory information presented by electronic means. General indications or symbols (such as the ‘i’) are not sufficient to fulfil the requirements of this provision. As stated in Article 18(1) of the FIC Regulation, a heading (text) should be used next to the QR code that clearly indicates the purpose of the QR code. This text should contain the word ‘Ingredients’. The suggestions are to use the expressions: "ingredients" ή "ingredients and nutritional values" ή "ingredients/nutritional values"The expression "ingredients» It can be written in any EU language, however if the label is in English, it would be better to write it in English as “ingredients”.
- Where the nutrition declaration and/or the list of ingredients are provided by electronic means, the link (QR code or similar code) to the nutrition declaration and/or the list of ingredients must be presented on the label in the same field of vision as the other mandatory particulars.
- Where the full list of ingredients is provided by electronic means, substances causing allergies or intolerances must be presented on the packaging or on the attached label, but not necessarily in the same field of vision as other mandatory information (the derogation in Article 40(2) of Delegated Regulation (EU) 2019/33 applies).
The QR code.
- Size: According to international standards (ISO/IEC 15415) the QR code must be at least 11,49 mm x 11,49 mm. Then, there should be a blank margin to bring the total size to 14,66 x 14,66 mm.
- It should have high contrast, ideally black on white
- You can have two QR codes, one for marketing, but there should be no confusion as to which is which.
For all wine products that have undergone a de-alcoholisation process and have an actual alcoholic strength by volume of less than 10%, it is appropriate to indicate the date of minimum durability on the physical label.
Useful information:
Wine Legislation: Mandatory Indications of Wine Products Based on EU and National Legislation
Typical values for fat, protein and salt in the nutrition declaration of wines
Frequently Asked Questions (FAQ)