In the context of the Directive, products are wines, sparkling wines and aromatised wines.

The wine spritzer is merely a "wine-based drink". These drinks are not regulated by the EU regulation. You are therefore still not obliged to provide a table of nutritional values or a list of ingredients.

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.

A product is considered to be produced, after all the necessary oenological processes have been applied and it has achieved the properties required for the product in accordance with the EU Market Regulation.
After the official legal part, let's take a look at what that means for you:
For example, a wine is considered to have been produced when it has reached the required alcohol content or acidity. In the case of sparkling wines produced by secondary fermentation, we need to take a closer look: Here, the second fermentation must have taken place AND the product must have reached the prescribed alcohol content, as well as overpressure. The cut-off date here is 8 December 2023.
A vinification of the base wines or the production of a cuvée does not change the labelling obligation.
A frizzante is also ready when it has reached the carbon dioxide overpressure.

The kilocalories or kilojoules and allergenic substances must be printed on the label. Everything else can be accessed via the QR code.

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.

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.

If you decide against a QR code solution and you explicitly print your list of ingredients on the label, the statement "Contains sulphites" is omitted. If you decide in favour of a QR code on the label, the statement "Contains sulphites" is still required on the label.

The following applies to quality wines: In future, these values will be indicated on the notification for the quality wine test number. For all other products, you can easily calculate the calorific value using our tool when entering all other information. For armoatised wines, it is recommended that they be analysed in a food laboratory.

In general, 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. These must still be listed. Our motto at this point: "Better safe than sorry!"

The following table is for your information only. Of course, we have already stored all of this in our system.
The following also applies: substances for deacidification do not usually remain in the end product and are therefore categorised as processing aids. They do not have to be mentioned in the list of ingredients.

Additives are the ones listed here:

Acidity regulators
Tartaric Acid D,L- or its neutral potassium salt
Malic Acid (D, L-; L-), E296
Lactic Acid, E270
Calciumsulphate, E516
Citric Acid, E330

Preservatives and antioxidants
Sulphur Dioxide
Caliumbisulfit
Calium Metabisulfit
Calium Sorbate
Lysozyme, E1105
L-Ascorbic Acid, E300
Dimethyl Dicarbonate, E242

Stabilisers
Citric Acid, E330
Metatartaric Acid, E353
Gum Arabic, E414
Yeast mannoproteins
Carboxymethyl Cellulose, E466
Caliumpolyaspartate
Fumaric Acid, E297

Gases and packing gases
Argon, E938
Nitrogen, E941
Carbon Dioxide, E290

The additive class of citric acid depends on the intended use (acidification or stabilisation).
Lysozyme can be used both as an additive (remains) and as a processing aid (removed).

In Annex I Part A Table 2 of EU Regulation 2019/934, the oenological processing substances are listed with regard to their classification as additives (can be found in Google search for Directive [EU] No. 2019/934 - click on "consolidated version"; the annex contains all oenological substances, differentiated according to "additive" and "processing aid").

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.

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.

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.

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.

You can either duplicate an existing QR code and then adapt it if you only want to adjust small details. Or, you can alternatively simply upload your lab reports and the corresponding QR code will be created automatically for each lab report.

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".

Sometimes that happens. And even though we always try our best to prevent this from happening, sometimes two pieces of the puzzle just don't fit together. But don't worry, we'll find a solution. If you are unhappy, you will get your money back. Of course, this is not possible for an unlimited period of time. That's why we said: If you find out within 6 months that something doesn't fit, there's no discussion. Unfortunately, we can no longer offer this after 6 months.