EU wine labelling rules, explained

1.What it is about

The European Union (EU) labelling law for wine regulates the labelling of wine bottles from now (December 8th 2023) in order to provide consumers with information about the origin, year, alcohol content and other relevant details. This includes information on the geographical origin, grape variety, quality level and potentially allergenic ingredients. The labelling regulations are intended to authenticity and quality of wine products and to help consumers choose and buy wine.

2.When the obligation applies

Starting on the 8th of December 2023, labels on wine bottles must contain nutritional information and a list of ingredients. The change applies to all wines produced after this date. If the wine was produced before the 8th of December 2023, there is no obligation to provide the list of ingredients and the nutrition declaration. To answer existing questions about the new regulation, the European Commission has published a catalogue of questions and answers (C/2023/1190). One of the questions was, for example, when a wine is considered to be produced. This is the case when the required acidity and alcohol content has been reached. An exception applies to sparkling wine. This is only considered to be produced when the second fermentation has taken place and it has reached its alcohol content and overpressure. All base wines or cuvées for which the tirage filling takes place shortly before and after the deadline require a list of ingredients and a nutritional table. Imported wines that were imported before this date also fall under this exemption. Imported wines that only reach their existing minimum alcohol content after the 8th of December 2023 are not covered by the exemption.

3.What belongs in the ingredient list

As with other products, it is also intended in this case, that the ingredients are listed in descending order of weight in which they were used in production. All ingredients that make up less than 2% of the final product can be listed at the end in any order.

Basically, you do not have to list additives that are only used as aids. However, it is important that you bear in mind that some additives can trigger allergies and intolerances. In this case, they must be listed. Our motto at this point: "Better safe than sorry!"

4.Nutrition declaration and energy value

The nutrition declaration covers energy, fat, saturated fat, carbohydrate, sugars, protein and salt, each per 100 ml. On the label itself the energy value is enough; the full table may be provided electronically. The energy value is derived from alcohol, residual sugar, organic acid and polyols.

If you enter the value of the alcohol content, sugar content and organic acidity in the table, the energy value is automatically displayed and then, if you want to, also displayed via the QR code.

5.In which languages

The list of ingredients must be provided in all national languages of the countries in which the wine is sold. However, so that you don't have to worry, the information on WineQR is automatically displayed in all EU languages.

6.The QR code on the label

The QR code must presumably have a minimum size of 1cm x 1cm. It is important that the QR code can be read by all devices without restrictions.

In addition to the label, the QR code must also be displayed in the online shop and on price lists. However, so that not everything is full of QR codes, there is a superordinate QR code that you can insert on the price list, for example, which then refers to all your existing overviews. Keep in mind, however, that this superordinate QR code may not be used on the label of the wine bottle. A "one-click solution" must be used here. Here you must use the standard QR code, which leads directly to the overview "with one click".

7.What the QR code must not do

Of course, the question arises as to whether it would be possible to make a virtue of necessity and, if you are already obliged to integrate the QR code function into the process, you could still place one or two references to other products. Unfortunately, the regulation is very clear here. It states that no marketing content may be displayed. There is still a lack of clarity with regard to web links and further menus. These may be permitted as long as they do not restrict the actual purpose of the online presentation. But we will probably have to wait a little longer until there is a clear answer.

Personal data may not be collected. Meanwhile, there is still disagreement regarding the evaluation of the scan rate or the localisation of areas via the IP address.

8.Recycling information

At the moment, everyone who sells their products in Italy needs to be careful. This is because information relating to recycling is already mandatory here. So we'll have to wait and see what happens in the other countries. However, the function is available to everyone on WeinQR.

9.How to do it with Wein QR

Each wine needs its own e-label, but you don’t have to start from scratch. Duplicate an existing e-label and change only what differs, such as the vintage or nutrition values. The copy is a separate e-label with its own QR code.

1. 01Enter your wine information
2. 02Add ingredients and allergens
3. 03Generate and download your E-Label