Regulatory Framework
- E-label (Electronic Label)
- A digital label accessible via QR code on the wine bottle, providing consumers with mandatory product information such as ingredients, nutrition declarations, and allergens. E-labels were introduced under the 2021 EU wine regulation reform and allow producers to meet labelling obligations electronically rather than printing all details on the physical label.
- What are e-labels and why do winemakers need them?
- CMO Regulation (Common Market Organisation)
- Regulation (EU) No 1308/2013, the primary legislation governing the EU's agricultural markets, including wine. It sets rules on wine categories, labelling, geographical indications, oenological practices, and trade. The 2021 amendment via Regulation (EU) 2021/2117 introduced the requirement for ingredients and nutrition information on wine labels.
- Regulation (EU) 2021/2117
- The amending regulation that reformed the CMO rules for wine labelling. It mandated that from 8 December 2023, all wines produced and labelled after that date must declare their full ingredients list and nutrition information, either on the physical label or via an e-label. This regulation is the legal basis for the current e-label requirements across the EU.
- Understanding the new EU wine label regulations
- Delegated Regulation (EU) 2023/1606
- A Commission delegated regulation that specifies the detailed rules for how wine ingredient lists and nutrition declarations must be presented. It covers the format of the e-label, the order of ingredients, how allergens must be highlighted, and the conditions under which electronic means may be used instead of physical labelling.
- Commission Notice C/2023/1190
- An interpretive guidance document published by the European Commission to help producers and national authorities apply the new wine labelling rules. While not legally binding, it clarifies ambiguities around transitional periods, stock exhaustion rules, ingredient listing for multi-vintage wines, and the technical requirements for QR codes linking to e-labels.
- PDO (Protected Designation of Origin)
- A quality scheme recognising wines whose production, processing, and preparation all take place within a specific geographical area, using recognised know-how. PDO wines must comply with strict production rules defined in a product specification. Examples include Chianti Classico DOCG, Champagne, and Rioja DOCa.
- PGI (Protected Geographical Indication)
- A quality scheme for wines where at least one stage of production, processing, or preparation takes place in a defined geographical area. PGI rules are generally less restrictive than PDO, allowing more flexibility in grape varieties and winemaking techniques. Examples include Terre Siciliane IGT and Pays d'Oc IGP.
- GI (Geographical Indication)
- An umbrella term covering both PDO and PGI designations. A geographical indication identifies a wine as originating from a specific region where its quality, reputation, or other characteristics are linked to its geographical origin. The EU wine GI system is managed through the CMO Regulation.
Labelling Requirements
- Nutrition Declaration
- The mandatory statement of nutritional information on a wine label or e-label. For wine, this includes at minimum the energy value. The full declaration (fat, saturates, carbohydrate, sugars, protein, and salt) may appear on the e-label. Values are expressed per 100 ml of the product as sold.
- How to calculate wine energy values for EU labels
- Energy Value (kJ / kcal)
- The amount of energy in a wine, expressed in kilojoules (kJ) and kilocalories (kcal) per 100 ml. For wine, energy primarily comes from alcohol and residual sugar. The energy value must appear on the physical label (at minimum as kJ/kcal per 100 ml), even when full nutrition details are provided via e-label.
- Calculate wine energy values with our guide
- Ingredients List
- A complete listing of all substances used in winemaking that remain present in the final product. This includes grapes, added sugars, acidifying or de-acidifying agents, stabilisers, preservatives (such as sulphites), and gases. Ingredients must be listed in descending order of weight as used during production. Processing aids that are no longer present in the finished wine are not required to be listed as ingredients, but certain ones must still be declared as allergens.
- Wine ingredients on labels: EU rules and examples
- Allergen Declaration
- The mandatory disclosure of allergens present in wine above regulatory thresholds. In wine, the main allergens are sulphites (above 10 mg/L), and proteins derived from milk (casein, potassium caseinate) or eggs (albumin, lysozyme) used as fining agents. Allergens must be highlighted in the ingredients list using distinct typography (such as bold) and displayed with standardised pictograms on the physical label.
- Wine allergen labelling: sulphites, egg, and milk rules
- Sulphites / Sulfites
- Sulphur dioxide (SO₂) and its derivatives, used as preservatives and antioxidants in winemaking. When present at levels above 10 mg/L (which applies to virtually all wines), sulphites must be declared as an allergen on the label using the phrase "contains sulphites" accompanied by the standardised allergen pictogram. The spelling "sulphites" is standard in EU English-language regulations.
- Guide to sulphites and allergen labelling
- Fining Agents
- Substances added to wine to clarify it by binding to and removing unwanted particles. Common fining agents include bentonite (clay), egg albumin, casein (milk protein), isinglass (fish-derived), and PVPP (polyvinylpolypyrrolidone). When fining agents derived from allergens (milk, eggs) are used and traces remain detectable, they must be declared as allergens on the label.
- Fining agents and allergen disclosure
- Processing Aids
- Substances used during winemaking that do not remain present in the final wine in significant quantities. Unlike ingredients, processing aids are not required to be listed in the ingredients list. However, if a processing aid is derived from an allergenic substance (such as egg or milk proteins used in fining) and traces may remain, the allergen must still be declared.
- Lot Number
- An identification code printed on the wine label (usually preceded by the letter "L") that identifies a specific production batch. Lot numbers are mandatory under EU Directive 2011/91/EU and allow traceability in case of product recalls or quality issues. The lot number must appear on the physical label and cannot be replaced by an e-label.
- Net Quantity
- The volume of wine in the container, expressed in litres (l), centilitres (cl), or millilitres (ml). Standard wine bottles are 750 ml (75 cl). Net quantity must appear on the physical label in a specified minimum font size that varies according to the volume of the container.
- Actual Alcoholic Strength
- The measured alcohol by volume (ABV) of the finished wine, expressed as a percentage followed by "% vol." This must be stated on the physical label with a tolerance of plus or minus 0.5 % vol. for most still wines (0.8 % vol. for certain PDO/PGI wines) and must be expressed in units or half units.
- Nominal Volume
- The standard volume indicated on the wine container, as opposed to the actual fill volume. EU legislation mandates specific nominal volumes for pre-packaged wines (such as 187.5 ml, 250 ml, 375 ml, 500 ml, 750 ml, 1 L, and 1.5 L). Wines may only be sold in these prescribed sizes when marketed in the EU.
Wine-Specific Terms
- Dosage / Liqueur d'expédition
- A mixture of wine and sugar added to sparkling wine after disgorgement to adjust the final sweetness level. The dosage determines the sweetness category (Brut Nature, Extra Brut, Brut, etc.) and its sugar content must be factored into the nutrition declaration. In the EU, the sugar content of the dosage must be reflected in the declared residual sugar and energy values on the e-label.
- Sparkling wine e-label compliance guide
- Residual Sugar
- The amount of natural grape sugar remaining in wine after fermentation, measured in grams per litre (g/L). Residual sugar affects both the wine's perceived sweetness and its energy value. For labelling purposes, residual sugar contributes to the carbohydrate and energy calculations in the nutrition declaration.
- Sweetness Categories (Sparkling Wine)
- Legally defined sugar ranges for sparkling wines. Brut Nature: 0–3 g/L (no added sugar). Extra Brut: 0–6 g/L. Brut: 0–12 g/L. Extra Dry: 12–17 g/L. Dry (Sec): 17–32 g/L. Demi-Sec: 32–50 g/L. Doux (Sweet): over 50 g/L. These categories must correspond to the actual measured sugar level after dosage.
- Sweetness categories for Prosecco, Cava, and Champagne
- Vintage Year / Millésime
- The year in which the grapes were harvested. If declared on the label, at least 85% of the grapes used must come from the stated harvest year (under EU rules). Vintage year is optional but, once declared, becomes a regulated claim. Multi-vintage wines (common in sparkling wine and some fortified wines) do not carry a vintage year.
- Varietal Wine
- A wine labelled with the name of a specific grape variety (such as Chardonnay, Merlot, or Tempranillo). Under EU law, if a single variety is named on the label, at least 85% of the wine must be made from that variety. If two or more varieties are named, they must be listed in descending order and together account for 100% of the wine.
- Traditional Method / Méthode Traditionnelle
- A sparkling wine production method where the second fermentation (which creates the bubbles) takes place inside the individual bottle. Used for Champagne, Cava, Franciacorta, and Crémant. The process involves riddling (remuage) and disgorgement (dégorgement). On e-labels, wines made by this method may have additional ingredients from tirage and dosage liqueurs.
- Traditional method sparkling wine labelling
- Charmat Method
- A sparkling wine production method where the second fermentation takes place in large pressurised tanks (autoclaves) rather than in individual bottles. This method is commonly used for Prosecco, Lambrusco, and Asti. The Charmat method typically results in different ingredient lists than the traditional method, as tirage liqueur and riddling agents are not used.
- Charmat method and Prosecco e-labels
- Must Enrichment / Chaptalization
- The practice of adding sugar (sucrose) or concentrated grape must to grape juice before or during fermentation to increase the final alcohol level. Permitted under EU law in certain wine-growing zones (primarily cooler climates in Zone A and B), chaptalization is regulated by the CMO Regulation and any added sugars must be reflected in the ingredients list.
Digital & Technical
- QR Code
- A two-dimensional barcode that, when scanned with a smartphone, directs the user to a web page containing the wine's e-label information. Under EU wine regulations, a QR code is the standard mechanism for providing consumers with electronic access to the ingredients list and nutrition declaration. The QR code must be accompanied by the text "ingredients" or its equivalent in the applicable language(s).
- QR codes on wine bottles: questions answered
- GS1 Digital Link
- A standard developed by GS1 that encodes product information (such as GTIN, batch, and serial numbers) into a URI structure within a QR code. GS1 Digital Link allows a single QR code to serve multiple purposes: consumer-facing e-label content, supply chain logistics, and regulatory traceability. While not mandatory for EU wine e-labels, it is increasingly adopted by larger producers for operational efficiency.
- Hreflang
- An HTML attribute (rel="alternate" hreflang="x") that tells search engines which language version of a page to serve to users in different regions. For multilingual wine e-labels, hreflang tags help ensure that consumers scanning a QR code in France see the French-language version, while those in Germany see the German version.
Compliance & Enforcement
- ICQRF (Italy)
- Ispettorato Centrale della Tutela della Qualità e della Repressione Frodi dei Prodotti Agroalimentari. Italy's central inspectorate for quality protection and fraud repression in agri-food products, including wine. ICQRF is the primary enforcement body for wine labelling compliance in Italy, conducting inspections and issuing penalties for non-compliant labels.
- E-label compliance in Italy: ICQRF enforcement
- AESAN (Spain)
- Agencia Española de Seguridad Alimentaria y Nutrición. Spain's food safety and nutrition agency, responsible for overseeing food labelling compliance including wine. AESAN coordinates with regional authorities (comunidades autónomas) to enforce labelling rules, and can impose fines for inaccurate or missing allergen or ingredient information.
- E-label compliance in Spain: AESAN and regional enforcement
- DGCCRF (France)
- Direction Générale de la Concurrence, de la Consommation et de la Répression des Fraudes. France's directorate for competition, consumer affairs, and fraud repression. DGCCRF inspectors verify wine labelling compliance, including e-label content, allergen declarations, and origin claims. France is one of the most active enforcers of wine labelling regulations in the EU.
- Food Information to Consumers (FIC) Regulation
- Regulation (EU) No 1169/2011, the EU's overarching food labelling law. FIC establishes general requirements for nutrition declarations, allergen labelling, ingredient lists, and font sizes on food labels. Wine was historically exempt from certain FIC provisions (ingredients and nutrition), but Regulation (EU) 2021/2117 removed most of these exemptions, bringing wine into alignment with other food products.
- How FIC now applies to wine labelling
- Stock Exhaustion / Transitional Period
- The period during which wines produced and labelled before 8 December 2023 may continue to be sold with the old labelling format (without ingredients or nutrition information). These wines can remain on the market until stocks are exhausted, with no fixed end date. Only wines produced or labelled after 8 December 2023 must comply with the new e-label requirements.
- Non-compliance penalties and transitional rules
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