What Happens If Your Wine Labels Aren't EU Compliant? Fines, Recalls & How to Fix It

If you produce or sell wine in the European Union, there is a reasonable chance you have heard about the new labeling rules. But many winemakers still underestimate what happens when those rules are not met. This is not a theoretical risk. Enforcement is active, and the consequences are real.

This article breaks down what the regulations actually require, what can go wrong if your labels fall short, where the most common compliance gaps are, and how to bring your wines into line quickly.

The Regulation: What Does EU Law Actually Require?

The key legislation is Regulation (EU) 2021/2117, which amended the earlier Common Market Organisation (CMO) regulation for wine. Specifically, Article 119(5) of Regulation (EU) 1308/2013 (as amended) now mandates that wine labels include:

• A full list of ingredients, including additives and allergens.
• A nutrition declaration per 100 ml (energy, fat, carbohydrates, sugars, protein, salt).

These requirements entered into force on December 8, 2023, and apply to all wines and aromatised wine products produced from the 2024 harvest onward.

Wines produced before that date may continue to be sold until stocks are exhausted, but anything bottled from the 2024 vintage forward must comply.

Producers may provide the ingredients list and nutrition table via an e-label, a digital page accessible through a QR code on the bottle. However, allergens and the energy value (the "E" symbol) must always appear on the physical label itself.

What Happens When Wine Labels Are Non-Compliant?

The EU does not directly impose fines at the Union level. Instead, enforcement is delegated to individual member states, which means the consequences depend on where your wine is sold. In practice, here is what you are looking at:

Removal from Sale

The most immediate consequence. Customs and market surveillance authorities in any EU member state can order non-compliant products removed from shelves or blocked at the border. If your wine arrives in Germany, France, or Italy without the required labeling, it may not make it to the shop floor.

Financial Penalties

Fines vary widely across member states because each country enforces EU food labeling law through its own national legislation. Examples:

• Italy enforces labeling violations under Legislative Decree 231/2017 (implementing Regulation 1169/2011). Administrative fines for missing or incorrect mandatory information can range from roughly 3,000 to 24,000 euros per infringement.
• France applies penalties under the Code de la consommation. Infractions related to misleading or incomplete labeling can result in fines and, in serious or repeat cases, criminal proceedings.
• Germany enforces through the Lebensmittel- und Futtermittelgesetzbuch (LFGB). Penalties for labeling violations can reach up to 50,000 euros depending on severity.
• Spain applies sanctions under food safety law (Ley 17/2011), with fines that can scale from minor infractions to amounts exceeding 60,000 euros for serious violations.

The exact figure depends on the violation, whether it is a first offense, and how cooperative the producer is. But even at the lower end, a 3,000-euro fine exceeds what many small wineries spend on labels in an entire year.

Market Restrictions

Repeated non-compliance or a serious violation can lead to broader restrictions. Authorities can flag a producer or importer, making future shipments subject to heightened scrutiny. For producers who export across multiple EU markets, one enforcement action can trigger increased inspections at other border points.

Reputational Damage

A recall notice that reaches one distributor tends to reach all of them within days. That kind of exposure damages relationships with importers and retailers. Some retailers now require proof of e-label compliance before listing new wines. Failing a compliance check does not just affect one shipment, it can affect your commercial standing.

Common Compliance Gaps: Where Producers Get It Wrong

Based on what we see from producers using our platform and from questions we receive, these are the most frequent mistakes:

1. Missing Ingredients List

The most basic gap. Many producers still treat the ingredients list as optional or believe that listing allergens on the physical label is sufficient. It is not. A complete ingredients list, including additives such as sulfites, stabilisers, and acidity regulators, must be available, whether on the physical label or via the e-label.

2. No Nutrition Declaration

Some producers skip the nutrition table entirely, or provide only the energy value. The regulation requires a full declaration per 100 ml: energy (kJ and kcal), fat, saturated fat, carbohydrates, sugars, protein, and salt. Omitting any of these fields puts the label out of compliance.

3. Tracking and Analytics on E-Labels

This is a subtle but serious issue. The regulation explicitly states that e-labels must not collect or track user data. That means no cookies, no analytics scripts, no visitor tracking of any kind on the compliance page. Producers who host e-labels on their own websites or use marketing-oriented QR platforms often violate this requirement without realizing it. Google Analytics on an e-label page, for example, makes the entire label non-compliant.

4. Marketing Content on E-Labels

The e-label page must contain only mandatory compliance information. No tasting notes, no winery history, no purchase links, no promotional banners. If your QR code leads to a page that mixes compliance data with marketing material, it does not meet the legal standard.

5. Non-Product-Specific QR Codes

Each QR code must link to information specific to that product. A generic QR code that leads to a winery homepage or a page covering multiple wines is not compliant. One SKU, one QR, one e-label.

6. Missing Physical Label Elements

Even when the e-label is perfect, the physical bottle must still show:

• Allergens (e.g., "Contains sulphites")
• Energy value (using the "E" symbol, e.g., "E 322 kJ / 77 kcal per 100 ml")

Producers sometimes assume the e-label replaces everything. It does not.

How to Fix It Fast

If your labels are not yet compliant, the practical steps are straightforward:

1. Audit your current labels. Check whether your physical label includes allergens and the energy value. Check whether your e-label (if you have one) includes a complete ingredients list and full nutrition table.

2. Remove tracking and marketing from your e-label page. If your e-label is hosted on a platform that includes analytics or promotional content, it needs to move to a compliant solution.

3. Generate compliant e-labels. A platform like ScanThisWine lets you fill in one form with your wine's details, ingredients, and basic data. It automatically calculates nutrition values, generates a compliant e-label page (no tracking, no marketing), translates it into all 24 EU official languages, and gives you a QR code as SVG or PNG ready for your label artwork.

4. Update your physical label artwork. Add the QR code with a caption such as "Ingredients & nutrition" and ensure allergens plus the energy value are printed on the bottle.

5. Test the QR. Scan it in different lighting conditions and at different distances to make sure it works reliably.

Generate a compliant e-label at scanthiswine.com, free.

Frequently Asked Questions

What regulation requires ingredients and nutrition on wine labels? Regulation (EU) 2021/2117 amended Article 119 of the CMO Regulation (EU) 1308/2013 to require a full ingredients list and nutrition declaration for wines from the 2024 harvest onward. The requirement entered into force on December 8, 2023.

Can I be fined for non-compliant wine labels? Yes. Each EU member state enforces labeling law through its own national legislation. Fines range from a few thousand euros to over 50,000 euros depending on the country, the severity of the violation, and whether it is a repeat offense. Products can also be removed from sale.

Does my e-label need to be in multiple languages? The e-label must be accessible in the official language(s) of the market where the wine is sold. In practice, supporting all EU languages from a single QR code is the simplest approach and avoids compliance issues when wines are distributed across multiple countries.

Can I use my winery website as the e-label? Only if the page contains exclusively mandatory information (ingredients, nutrition, allergens), has no marketing content, and does not track visitors in any way. Most winery websites include analytics and promotional elements, which would make the e-label non-compliant.

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Fix your labels before the next inspection. Create a free e-label at scanthiswine.com.