Wine labelling in the European Union (EU) has undergone significant changes with the introduction of the new Regulation (EU) 2021/2117. This article analyses these changes, in particular the needs that the changes have created, citing relevant parts of the law to illustrate how these needs should be addressed.
Changes to Labelling Requirements
The new regulation states that, as of 8 December 2023, all bottles of wine sold in the EU, regardless of their country of origin, must include nutritional information and a list of ingredients. This is in addition to the existing allergen and energy information requirements detailed in regulations 1169/2011 and 1308/2013.
Nutritional Information and Ingredients List
Two formats are introduced to present the nutritional information and the list of ingredients. The first is to add all information on the physical label of the bottle. The second is to show only the energy value on the physical label and provide the rest of the information (full nutrition information and list of ingredients) electronically, accessible via a QR code or Link. The physical label must present the energy value with the symbol "E" for "Energy".
Wine Product Category
According to Part II of Annex VII to Regulation (EU) No 1308/2013, bottles of wine must indicate one of the following categories: wine, new wine still in fermentation, liqueur wine, sparkling wine, quality sparkling wine, quality aromatic sparkling wine, and more. However, this category may be omitted if the wine label indicates the name of a protected designation of origin or a protected geographical indication.
Alcoholic strength by volume
The actual alcoholic strength by volume, to be indicated for beverages containing more than 1.2% alcohol by volume, shall be specified in percentage units or half-units, followed by the symbol "% vol".
Labelling for Different Origins and Types of Wine
The regulation also introduces new labelling requirements for wines of different origins and types.
Designation and Geographical Indications
Wines with a "protected designation of origin" or "protected geographical indication" must indicate this on the label next to the name of the designation of origin or geographical indication, without the need for translation. Wines without a protected geographical indication must indicate the country of origin.
Labels must ensure traceability, including "indication of provenance". The terms used shall vary between "wine from [...] ", "produced in [...] ", "product of [...] ", "wine from the European Union" or "wine from outside the European Union", as appropriate.
Obligations for Exporters
The Regulation also lays down rules affecting exporters to the EU. Wine producers outside the EU must comply with EU labelling rules to sell their product in the region. This means that even imported wines must display nutritional and ingredient information, just like wines produced in the EU.
Labelling of Organic and Biodynamic Wines
Organic and biodynamic wines are also subject to specific labelling rules. Organic wines must comply with Regulation (EU) 848/2018, which includes requirements for organic production and the EU Ecolabel. Biodynamic wines must comply with Demeter or Biodyvin standards, two of the main biodynamic certifications recognised in the EU.
Wines bottled or labelled before 8 December 2023
The new labelling regulations do not apply to bottles of wine that were bottled and labelled before 8 December 2023. This means that wine bottles produced and labelled before this date are not subject to the new labelling rules laid down by Regulation (EU) 2021/2117. These bottles can therefore continue to be marketed with their original labelling, as they complied with the regulations in force at the time of their production and labelling.
The new EU wine labelling rules provide more transparency for consumers and require a higher level of information on all bottles of wine sold in the EU. While it represents a significant change for producers, it also offers an opportunity to highlight the quality and specific characteristics of their wines.
Adaptation to these new requirements may take time and require some adjustments in the production and marketing process. Producers and exporters are therefore advised to start preparing as early as possible to ensure compliance with the new regulations.