Wine Allergen Labelling: Sulphites, Egg & Milk Rules Explained
Definitive guide to wine allergen labelling in the EU: which allergens must be declared, what the law actually says, and how to get it right on both the physical label and the e-label.
Wine Allergen Labelling: Sulphites, Egg & Milk Rules Explained
Allergen declarations cause more compliance errors than any other element of EU wine labelling. Unlike the nutrition table or the ingredients list, which can be moved to an e-label via QR code, allergens occupy a unique position: they must always be printed on the physical bottle. Get them wrong and you face a genuine food-safety compliance risk.
This guide covers everything a winemaker or bottler needs to know: which substances count, what the regulations actually say, the difference between "contains" and "may contain," and what a compliant declaration looks like in practice.
Which Allergens Apply to Wine?
EU food law identifies 14 categories of allergenic substances in Annex II of Regulation (EU) No 1169/2011. Three of those categories are directly relevant to winemaking:
1. Sulphites (Sulphur Dioxide / SO2)
Sulphites are by far the most common wine allergen. Nearly all wines contain SO2, either added as a preservative or produced naturally during fermentation. The declaration threshold is 10 mg/L: any wine with total SO2 at or above this level must declare sulphites.
2. Egg-derived Substances
Egg whites (albumin) have long been used as a fining agent to soften tannins, especially in red wines. Lysozyme, an enzyme derived from egg whites, is used as a microbiological stabiliser. Both are allergenic and fall under Annex II, category 3 (eggs and products thereof).
3. Milk-derived Substances
Casein and potassium caseinate, both derived from milk, are used as fining agents to remove unwanted colour or bitterness, particularly in white and rosé wines. They fall under Annex II, category 7 (milk and products thereof, including lactose).
Allergen Table: What Must Be Declared
| Substance | Source | Common Use in Wine | Must Declare? |
|---|---|---|---|
| Sulphur dioxide (SO2) | Chemical / fermentation by-product | Preservative, antioxidant | Yes — if >= 10 mg/L total SO2 |
| Albumin (egg white) | Egg | Fining agent (tannin removal) | Yes — if used and traces remain |
| Lysozyme | Egg | Microbiological stabiliser | Yes — if used and traces remain |
| Casein / potassium caseinate | Milk | Fining agent (colour/bitterness removal) | Yes — if used and traces remain |
| Isinglass | Fish (swim bladder) | Fining agent (clarification) | Yes — if used and traces remain |
| Bentonite | Mineral clay | Fining agent (protein stabilisation) | No — not an Annex II allergen |
| PVPP | Synthetic polymer | Fining agent (colour/phenol removal) | No — not an Annex II allergen |
| Pea protein | Plant | Fining agent (vegan alternative) | No — not an Annex II allergen |
Note that isinglass (derived from fish swim bladders) is also an Annex II allergen (category 4). While less common than egg or milk fining, it is used in some white wine and sparkling wine production and must be declared when present.
The Legal Basis
Two key regulations govern wine allergen labelling:
Regulation (EU) No 1169/2011 (the Food Information Regulation) Annex II lists the 14 categories of allergenic substances that must be declared on all food products, including wine. Article 21 requires that allergens be emphasised in the ingredients list (typically by bold text) and that the word "Contains" precede a standalone allergen declaration.
Regulation (EU) No 1308/2013 (the CMO), as amended by Regulation (EU) 2021/2117 Article 119 of the CMO sets out the mandatory particulars for wine labels. It explicitly requires allergen indication in accordance with the food information regulation. The 2021 amendment expanded mandatory information to include a full ingredients list and nutrition declaration, but critically, it also confirmed that allergens and energy must remain on the physical label even where an e-label (QR code) is used.
"Contains" vs "May Contain"
"Contains"
The word "Contains" followed by the allergen name is mandatory when the allergen is knowingly present in the finished wine above the relevant threshold. For sulphites, that threshold is 10 mg/L. For egg and milk derivatives used as fining agents, the obligation applies when residues remain in the finished wine, even in altered form.
A typical physical label declaration:
Contains sulphites, egg, milk
Or, using the more specific terms:
Contains sulphur dioxide, albumin, casein
"May contain" (Precautionary Labelling)
"May contain" (or "may contain traces of") is not required by EU law and is not harmonised at the EU level. It is a voluntary precautionary statement that producers may use when there is a genuine risk of cross-contamination — for example, if the same equipment is used to fine different wines with different agents without complete cleaning between batches.
Because it is voluntary, there is no standardised format. However, producers should use it responsibly: a blanket "may contain egg and milk" on every wine undermines the statement's usefulness for allergic consumers.
Pictograms vs Text
Since Regulation (EU) 2021/2117 came into effect, wine labels may use pictograms (small icons depicting egg, milk, etc.) in addition to text. These pictograms are defined in Commission Delegated Regulation (EU) 2023/1606.
Key points:
- Pictograms are optional, not mandatory.
- They supplement the text declaration; they do not replace it.
- The text-based "Contains..." statement remains the minimum legal requirement.
- When pictograms are used, they must comply with the specific design templates in the delegated regulation.
Many producers choose to include both text and pictograms for clarity, particularly on labels sold across multiple markets where consumers may not read the label language.
Physical Label vs E-Label: Where Must Allergens Appear?
Allergens MUST appear on the physical bottle label. They cannot be moved exclusively to the e-label. The e-label (QR code) is permitted for the full ingredients list and the complete nutrition declaration, but the following must always be printed directly on the bottle:
- Allergen declaration — "Contains sulphites" (and egg/milk if applicable)
- Energy value — using the "E" symbol (e.g. E 322 kJ / 77 kcal per 100 ml)
This rule is explicit in Article 119 of the amended CMO and in Delegated Regulation (EU) 2019/33. There is no exemption, regardless of label size or format.
On the e-label, allergens should also be repeated within the ingredients list (emphasised in bold), but this is in addition to the physical label, not instead of it.
Processing Aids vs Ingredients: The Key Distinction
This distinction causes the most confusion in allergen labelling.
Ingredients are substances that remain in the finished wine and must be listed in the ingredients list. Additives such as sulphur dioxide (when used as a preservative) are ingredients.
Processing aids are substances used during production but not intended to remain in the final product. Fining agents (albumin, casein, isinglass, bentonite) are typically classified as processing aids.
Here is the critical rule: even when a substance is a processing aid, if it is an allergen listed in Annex II and residues remain in the finished wine (even in altered form), it must still be declared as an allergen. This is stated explicitly in Article 9(1)(c) of Regulation 1169/2011.
In practice, this means:
- Bentonite (not an Annex II allergen) — used as a fining agent, no allergen declaration needed, does not appear in the ingredients list.
- Casein (Annex II allergen, category 7) — used as a fining agent, must be declared as an allergen if residues are detected or cannot be excluded.
- Lysozyme (Annex II allergen, category 3) — used as a stabiliser, must be declared if residues remain.
Detection Thresholds and Trace Amounts
EU law does not set a specific analytical threshold below which egg or milk residues from fining can be considered absent. Unlike the 10 mg/L threshold for sulphites, there is no quantified "safe limit" for egg or milk proteins in wine.
In practice, the winemaker must demonstrate through good manufacturing practice and, where appropriate, analytical testing (ELISA methods are commonly used) that residues have been removed. The burden of proof rests with the producer. If there is any doubt about whether fining agent residues remain, the allergen should be declared.
The European Food Safety Authority (EFSA) has assessed casein and egg-derived fining agents and concluded that residues below certain levels are unlikely to trigger reactions. However, these findings have not been codified into law as formal exemption thresholds, so the cautious approach is to declare unless analytical evidence confirms absence.
Practical Example: What a Compliant Declaration Looks Like
On the physical bottle label:
Contains sulphites, milk
E 340 kJ / 81 kcal per 100 ml
Or with pictograms:
Contains sulphites 🥛
E 340 kJ / 81 kcal per 100 ml
On the e-label (within the ingredients list):
Ingredients: Grapes, sugar, sulphur dioxide, acidity regulator (tartaric acid). Fined with casein (milk-derived).
The allergen terms are emphasised in bold within the ingredients list, and the standalone allergen declaration is on the bottle.
Frequently Asked Questions
Q: If my wine contains less than 10 mg/L of SO2, do I need to declare sulphites? No. The declaration threshold for sulphites is 10 mg/L total SO2. Below this level, no sulphite declaration is required on the label. However, truly sulphite-free wines are rare, since fermentation itself produces small amounts of SO2.
Q: I fined my white wine with casein but then filtered it thoroughly. Do I still need to declare milk? If you can demonstrate through validated analytical testing that milk protein residues are no longer detectable in the finished wine, you may have grounds not to declare. However, the burden of proof is on you. If there is any uncertainty, the safe and legally sound approach is to declare "Contains milk."
Q: Are pictograms mandatory on wine labels? No. Pictograms for allergens are optional. The text-based "Contains..." declaration is the legal minimum. Pictograms may be used in addition to text but never instead of it.
Q: Can I put the allergen declaration only on the e-label and skip the physical bottle? Absolutely not. This is one of the most common mistakes. Allergen declarations must always appear on the physical bottle label. The e-label can repeat them within the ingredients list, but it cannot be the sole location. This requirement is non-negotiable under Articles 119 of the CMO and Article 9 of Regulation 1169/2011.
Skip the Guesswork on Allergens
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