Exporting Wine to the EU? E-Label Requirements for Non-EU Producers

If you produce wine in the United States, Australia, Chile, Argentina, South Africa, New Zealand, or anywhere else outside the European Union, and you sell, or want to sell, that wine in Europe, you must comply with EU labelling regulations. The rules do not distinguish between EU-produced and imported wine. If the bottle reaches a European shelf, it must meet European standards.

This guide explains the exporting wine to EU labelling requirements that matter most for non-EU producers, the common mistakes exporters make, and how to get compliant quickly and at no cost.

Who Needs to Comply?

The answer is simple: every wine sold in the EU must comply with EU labelling rules. This applies equally to a Napa Valley Cabernet, a Marlborough Sauvignon Blanc, a Mendoza Malbec, and a Stellenbosch Pinotage.

The legal basis is Regulation (EU) 2021/2117, which amended the EU wine labelling framework, along with Article 119 of the CMO Regulation and the general Food Information to Consumers Regulation (EU) No 1169/2011 (often called FIC). Together, these regulations require wines from the 2024 harvest onward to provide detailed ingredient and nutrition information to EU consumers.

Who bears legal responsibility?

The importer or first EU-based operator placing the wine on the market bears the legal responsibility for compliance. In practice, this means your European distributor or importer is the one who could face enforcement action if your labels are non-compliant.

However, producers who proactively provide compliant information gain a real advantage:

• A wine that arrives with a ready-to-use e-label and correct data saves the importer time, money, and legal risk.
• Non-compliant wines may be refused at the border or delisted by importers who do not want the compliance burden.

What Non-EU Producers Must Provide

The requirements for imported wines are exactly the same as for EU-produced wines. There is no lighter set of rules for third-country producers.

1. Ingredients List

A full list of ingredients must be available to the consumer. This includes:

• Grapes (or grape must)
• Additives used in production (e.g., sulfur dioxide, tartaric acid, gum arabic)
• Processing aids - only if they are allergens still present in the finished wine
• Ingredients must be listed using EU-standard terminology and category names

2. Nutrition Declaration (per 100 ml)

The nutrition table must include:

• Energy in kJ and kcal
• Fat (of which saturates)
• Carbohydrates (of which sugars)
• Protein
• Salt

For most wines, fat, protein, and salt will be 0 or near-zero. The energy value is largely driven by alcohol content and residual sugar.

3. Allergens on the Physical Label

Allergens must appear on the physical bottle label, not just on the e-label. The most common wine allergens are:

• Sulfites (sulphur dioxide and sulphites at concentrations above 10 mg/l)
• Milk and milk-based products (used as fining agents)
• Egg and egg-based products (used as fining agents)

The physical label must include a "Contains..." statement (e.g., "Contains sulfites").

4. Energy Value on the Physical Label

The energy value (in kJ/kcal per 100 ml) must also appear on the bottle itself. It may use the compact "E" symbol format.

5. E-Label via QR Code

The full ingredients list and nutrition declaration can be provided through an e-label, a digital page linked via a QR code on the bottle. This is how most producers handle compliance, because printing all the information directly on the label is impractical for multilingual markets.

The e-label must follow strict rules:

• No marketing content on the compliance page
• No tracking or data collection from consumers
• Product-specific - one QR code per wine/SKU
• Multilingual - accessible in the official languages of the EU market where the wine is sold

Country-by-Country: What Exporters Often Get Wrong

Wine-producing countries outside the EU each have their own domestic labelling rules. A common and costly mistake is assuming that compliance with home-country regulations means compliance with EU rules. It does not.

United States

US wines follow TTB (Alcohol and Tobacco Tax and Trade Bureau) rules, which require allergen statements for sulfites but do not require a full ingredients list or nutrition declaration. American producers exporting to the EU must add both.

Australia

Australian wine labels follow Food Standards Australia New Zealand (FSANZ) rules. Australia requires allergen declarations, but uses different terminology (e.g., "sulphites" vs the EU's specific threshold of 10 mg/l) and does not require a nutrition table. A compliant Australian label is not automatically compliant in the EU.

Chile

Chile is one of the EU's largest wine suppliers. Chilean labelling rules require basic allergen and alcohol information but do not mandate a per-100 ml nutrition declaration or a full ingredients list. Chilean exporters must create separate EU-compliant documentation for those two items.

Argentina

Argentina's ANMAT food labelling rules do not require a per-100 ml nutrition declaration or a full EU-format ingredients list. Argentine producers selling into Europe need to provide both, which their domestic labels do not cover.

South Africa

South African wine labelling follows DALRRD regulations. South Africa requires allergen statements but does not mandate a per-100 ml nutrition table or a full ingredients list with EU-standard additive terminology. South African exporters must add both to meet EU requirements.

New Zealand

New Zealand shares the FSANZ framework with Australia. Like Australian producers, NZ wineries are not required to provide a full ingredients list or per-100 ml nutrition table domestically. Both must be added for EU-bound bottles, along with multilingual support.

Common Mistakes by Non-EU Wine Exporters

Based on what we see from producers using ScanThisWine, these are the most frequent compliance errors:

1. Assuming Home-Country Rules Are Sufficient

This is the single biggest mistake. No non-EU country currently requires the same level of ingredient and nutrition disclosure as the EU. If you label only for your domestic market, you are not EU-compliant.

2. Missing or Incorrect Allergen Declarations

Allergens must appear on the physical label using EU-standard terminology. Simply stating "contains sulfites" in a non-EU format or omitting milk/egg fining agent declarations can cause problems.

3. No Multilingual Support

The EU has 24 official languages. An e-label that only works in English will not satisfy requirements in markets like France, Germany, Italy, or Spain. Your e-label platform must handle translations automatically.

4. Using a Generic QR Code

Some producers link their QR code to a general website or marketing page. Under EU rules, the e-label QR code must link to a product-specific compliance page with no marketing and no tracking. A generic link is not compliant.

5. Forgetting the Physical Label Requirements

Even with an e-label, allergens and energy value must still appear on the physical bottle. The QR code does not replace these on-bottle requirements.

How ScanThisWine Handles This

ScanThisWine is a free e-label tool that works for any producer, anywhere. You fill in one form per wine, and the platform generates a regulation-compliant e-label page with automatic nutrition calculation, translations in all 24 EU languages, and a downloadable QR code, with no tracking on the label page.

Frequently Asked Questions

Do these rules apply to wines I already have in stock? Wines produced before 8 December 2023 are exempt from the new labelling requirements and may be sold until stocks are exhausted. However, any wine from the 2024 harvest onward must comply.

My importer says they will handle compliance. Do I still need to worry? Your importer is legally responsible, but they need accurate information from you, the producer, to create compliant labels. Providing a ready-made e-label removes friction, makes your wine more attractive to importers, and ensures accuracy.

Is an e-label mandatory, or can I print everything on the physical label? The e-label (QR code) is not technically mandatory. You may print the full ingredients list and nutrition declaration directly on the bottle. However, the e-label is strongly preferred because it saves label space, supports multiple languages automatically, and can be updated without reprinting.

Does my e-label need to be in every EU language? The e-label must be available in the official language(s) of the EU member state(s) where the wine is sold. Since most wines are distributed across multiple markets, supporting all EU languages is the practical approach. ScanThisWine handles this automatically.

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Next Steps

The EU's labelling requirements apply to every wine sold in Europe, no matter where it was made. Non-EU producers who get ahead of compliance make their wines easier to sell in Europe.

Create your free e-label at ScanThisWine.