FAQ on EU Regulation 2021/2117* (Wine Labeling Regulation)

What does the new EU regulation stipulate?

From December 8, 2023, all wines sold in the EU, similar to other food products, must be labeled with additional nutrition-related information. This includes mandatory information on nutritional values and ingredients on the wine labels. To better display this information, labels can be equipped with QR codes that link to a mobile website. (E-Label)

What steps are required?

From December 8, 2023, manufacturers are required to label products such as wine, sparkling wine, semi-sparkling wine, non-alcoholic wine, and flavored wine with a nutrition facts table and an ingredient list. The labels on wine bottles must continue to include information on allergens, energy content, volume, alcohol content, vintage, bottler, winery, and product name. If the newly required information is not provided via the label, an E-Label can be used. An E-Label consists of a QR code and an associated landing page that displays this information electronically.

Specific labeling options:

Labeling on the bottle label: It is possible to provide all required information on the traditional back label of the bottle. The guidelines mentioned must be followed. All information must be placed in the same visible area as the other mandatory information.

Labeling via an E-label: Alternatively, labeling can also be done digitally by placing a QR code on the back label, leading to a landingpage.This landing page must meet various technical and legal requirements, which are described further below in this document.

How is the production date defined:

A product is considered produced, once it has undergone all necessary oenological processes and meets the properties prescribed by the EU market regulation.

For wine, this means reaching the specified alcohol or acidity level. Except for ice wines, this means that wines only fall under this regulation starting from the 2024 harvest.

For sparkling wine produced by a second fermentation, it is considered produced only when this fermentation is completed and both the prescribed alcohol content and the pressure according to the EU market regulation are achieved, with the decisive date being December 8, 2023. The vinification of base wines or the creation of a cuvée before this date does not exempt from the obligation to label. Similarly, for frizzante, it is considered produced once the required carbon dioxide pressure is achieved.

For "partially dealcoholized wine" or "dealcoholized wine", the day of the dealcoholization is considered the date of production.

For flavored wine products, the day of flavoring is considered the date of production.

For "sparkling wine with added carbon dioxide" and "carbonated sparkling wine", the day when the carbon dioxide is added is considered the production date.

Representation of ingredient information:

The ingredient list must include all ingredients and additives used in production, with grapes always declared as the primary ingredient. Substances used for oenological processes such as enrichment and sweetening, including sucrose, concentrated grape must, and rectified concentrated grape must (RTK), must also be mentioned. This also applies to the carbon dioxide added in sparkling wine. Processing aids are exempt from the declaration requirement, unless they are known as allergens or intolerance triggers and are detectable within the applicable limits.

In WineSign.io, all these ingredients are predefined - you just need to select them.

How to specify the ingredient list:

The labeling of ingredients must be done in clearly legible font and with a minimum font size of 1.2 mm. The heading of the ingredient list should include the terms "Ingredients:", "Ingredient list:", or "Ingredient directory:". Within this list, all ingredients and additives are generally listed in descending order of their quantity at the time of use in the production process. Ingredients and additives that make up less than 2% of the total product may be listed at the end of the list in any order. In addition, additives are to be categorized according to their respective functions.

The mandatory functional categories for wine include:

Acid regulators
Preservatives and antioxidants
Stabilizers
Gases and packaging gases

The word "Ingredients:" is prefixed to the ingredient list. After that, the other ingredients are listed according to their quantity in descending order. For naming the ingredients, either the legally prescribed or generally accepted terms should be used. In addition, the category (class name) for each additive must be stated.

"Grapes" must always be mentioned at the beginning of the ingredient list. In the case of enrichment, "Sugar" or "Sucrose" is usually listed afterwards. When blending multiple wines, it is advisable to list all ingredients used, with elements like sugar, tartaric acid, or sulfur dioxide listed only once in the directory. Ingredients making up less than 2% of the final product may be listed at the end of the directory in any order, which often applies to numerous additives or processing agents.

Allergens are usually named as additives in the ingredient list and additionally visually marked. Generally, this is done in bold font. (Alternatives such as color or font style are also allowed). By naming the allergen in the ingredient list, there is no need to additionally state "contains sulfites" on the standard label. Consequently, the formulation in the ingredient list will now be: "Preservative: Sulfur dioxide or sulfites".

When using an E-label, unlike the traditional label, the statement "contains sulfites" persists and is listed at the bottom. In this digital labeling, no additional visual emphasis of the statement "contains sulfites" is required.

Special regulations for organic and ecological products:

Products produced according to the guidelines for organic cultivation may use terms such as "organic", "ecological", as well as corresponding abbreviations such as "bio-" or "eco-" in their labeling and advertising materials. These products usually consist entirely of ingredients from organic cultivation, which means no additional information in the ingredient list is necessary. Exceptions include specific ingredients or additives that are not available in organic quality and whose use is allowed according to EU law; these may be used up to a maximum of 5 percent. In such cases, organic ingredients and additives must be clearly labeled in the ingredient list, with the labeling matching the size, color, and style of the other information.

If you use WineSign.io, you don't have to worry about this point: We present the ingredient list correctly for you on the wine landing page.

Representation of nutritional information:

Nutritional information is preferably presented in tabular form. This should include the energy content as well as the amounts of fat, saturated fat, carbohydrates, sugar, protein, and salt.

The information must be provided in a clearly readable font, with a minimum font size of the small 'x' of 1.2 mm to be observed."

For ingredients that can be neglected due to their minimal proportion in the product, a shortened representation after the table is possible. This usually applies to wine. Nutritional information for liquids is to be given per 100 ml, while for solid products, the information is given in grams.

The nutritional information to be declared should be based on average values, either obtained through analyses by the manufacturer, calculated based on known or actual average values of the used ingredients, or based on generally accepted data. Winemakers are able to calculate the necessary nutritional information mostly from the available data on alcohol content, residual sugar, and total acidity. The nutritional values to be indicated are those at the time of sale, with particular attention to glycerin formed alongside the sugar in carbohydrates. The calorific value is to be indicated in kilojoules (kJ) and kilocalories (kcal), optionally under the terms "Calorific value" or "Energy".

If you use WineSign.io, you don't have to worry about this point: We present the nutritional information correctly for you on the wine landing page. With the built-in nutritional calculator, you just need to provide alcohol content, residual sugar, and acidity. WineSign.io takes care of the rest for you.

Language to be used:

The language used for the ingredient list and nutritional information must be easily understandable for consumers in the respective marketing country. In other words, you are legally secure if you present the necessary information in the official language of the country in question.

If you use WineSign.io, your data is automatically translated into the 24 official languages of the EU and displayed correctly in each country.

What details are mandatory on the E-Label?

Clear identification of the wine, including its name and optionally a picture.
Nutritional information per 100 ml
Energy value must be stated in kilojoules and kilocalories.
Carbohydrates and sugars must be stated in grams.
Fat, unsaturated fatty acids, protein, and salt are either listed in a table or textually represented as "Contains trace amounts of fat, saturated fatty acids, protein, and salt.
Ingredient list according to EU guidelines.
Labeling of allergens.
Additional data such as grape varieties, vineyard sites, quality levels, logos etc. may optionally be listed.
Whether logos of certificates such as "Organic" or "Sustainability" can be displayed on the landing page is currently not legally clear. Therefore, we currently advise against it.

WineSign.io supports all these needs.

Online shop and contracts outside the winery

For online sales and contracts concluded outside the physical winery, similar requirements regarding the provision of information on ingredients and nutrients apply as on-site. This means that manufacturers can list the ingredient list and nutritional information directly on the product page in their online shop, or alternatively provide a QR code or link through which this information is accessible via an E-label. This regulation also applies to order forms and price lists that integrate an order form. Thus, this requirement applies to all contracts concluded outside the business premises that enable the buyer to directly purchase the wine.

WineSign.io provides you with a real-time interface in JSON format, through which you can display all your wine data in your own or any other online shop. For price lists, you can create "collective QR codes" so that you only need to present one QR code per price list (via the collective QR codes, the consumer reaches a landing page displaying the wines of your choice).

Special labeling regulations:

Specific labeling regulations for wine according to the EU Commission under Article 48a of Regulation 2019/33 include:

The term "Grapes" can be uniformly used for grapes and grape must.
"Concentrated grape must" can be used for both concentrated grape must and rectified concentrated grape must (RTK).
Acid regulators and stabilizers may be indicated with a maximum of three alternative ingredients, provided that these are functionally similar or interchangeable and at least one of the additives is present in the finished product. The indication should be with the formulation "contains ... and/or ...", with the use of E numbers allowed.
Usual designations (e.g. sulfites) may be used for allergenic oenological substances in the ingredient list, provided that they are visually highlighted.
Substances used as packaging gases do not have to be listed individually. The note "bottled under protective atmosphere" or a similar formulation is sufficient. This does not apply to added carbon dioxide in sparkling wines.
The dosage for filling or for shipping is either to be indicated only by the terms "filling dosage" or "shipping dosage" or by adding a list of their respective components in parentheses.

How large should the QR code be printed?

There are no specific regulations; a size of 1cm x 1cm is recommended to ensure that the QR code can be read by currently circulating smartphones. (NOTE: For Italy, a QR code size of 1.5 cm x 1.5 cm is prescribed!)

WineSign.io provides you with printable QR codes in formats: .eps, .pdf, .png, .svg, and .webp.

Collective QR Codes:

According to EU Regulation (2021/2117), each wine product on the back label must have its own QR code. This means that each wine requires an individual QR code. However, for price lists where this information must also be provided for each wine, there is an exception. The legislation offers an elegant solution here: a single QR code can direct to a summary page that can display the information of all products listed on the price list collectively. This solution is referred to as "Collective QR Code."

WineSign.io also provides you with collective QR codes.

Technical and legal requirements for E-Labels:
No marketing context:

The EU regulation explicitly prohibits the display of marketing content or the direct sale of wines on the E-Label. Thus, linking to one’s own website is not possible.

No user tracking:

It is expressly forbidden to track users who visit the landing page in any way (e.g., via Google Analytics, etc. - including recording of IP addresses is prohibited).

WineSign.io naturally adheres to this rule.

How long must an E-Label be accessible?

The legislator states, "The E-Label must be accessible as long as the product is on the market." This statement is not very practical in the wine trade. It is assumed that the E-Label should be accessible for about 10 years.

WineSign.io provides you with the E-Label for as long as you need it!

Energy value:

The energy value must be stated both on the physical label and on the E-Label. It is calculated from the parameters of alcohol content, residual sugar content, acidity, and glycerin.

WineSign.io automatically calculates the energy values for you.

GDPR compliance:

The E-Label must meet all requirements of the GDPR - This includes the provision of a legal notice.

WineSign.io creates a correct legal notice from your information and complies with all legal provisions of the GDPR.

Recycling information:

In Italy and France, recycling information is mandatory according to EU Directive 97/129/EC. Learn more here.

With WineSign.io, you can easily implement and fulfill this information obligation.

*These FAQs are a summary of the key rules of EU Regulation 2021/2117.

Since there is still some room for interpretation, this summary should not be considered legally binding.