The new EU legislation on wine labeling came into force last August.
A provision that essentially changes everything: in addition to the specific obligations relating to wine in terms of geographical references, vines, etc., which remain, there are those regarding the indication of nutritional parameters and ingredients.
However, to facilitate the operation of the wineries without sacrificing the consumer’s need for information, the possibility of dividing the information between the paper label and a digital label is given, which can be reached with a QR-code printed on the paper label.
Another operationally important detail: the new regulation comes into force for all wines produced after 8 December 2023.
The EU Commission has yet to clarify what is meant by “products”. The orientation seems to be to refer the term to the must and the wine, not the bottling, then effectively starting the obligation from the 2024 harvest.
The wine sector aims to extend this interpretation also to sparkling wines, however it must be considered that in EU legislation sparkling winemaking is normally considered as new winemaking and therefore for these wines the obligation of the new label could come into force as early as this year.
Minimum indications that must appear on the paper label affixed to the bottle.
The label on the bottle must include:
– the energy content of the wine in kilocalories and kilojoules per 100ml of wine.
– substances that cause allergies or intolerances, whether ingredients, additives or technological aids and their derivatives.
As usual all indications must be in the same field of vision.
Indications that can be reported on the e-label linked to the QR-code.
If not already included on the label on the bottle, the e-label must report:
– The complete nutritional table with the data expressed per 100 ml of wine of:
o Kilocalories and Kilojoules.
o Total and saturated fats in grams.
o Total carbohydrates and sugars in grams.
o Proteins in grams.
o Salt in grams.
Is possible to express the data also per portion or consumption unit.
– The ingredients in decreasing order of weight, including those that may cause allergies or intolerances, the list of which must be preceded by the term “Contains”.
Note that the term “grapes” can be used to indicate the grapes/musts used as raw materials and the term “concentrated grape must” also includes rectified concentrated grape must.
Also note that technological aids, i.e. those substances not consumed as an ingredient in themselves, which are intentionally added to raw materials to achieve a specific technological objective, must NOT be indicated among the ingredients. The technological aids also include yeasts, which therefore should NOT be indicated in the ingredients.
Characteristics of the QR-code that leads to the e-label.
The electronic label containing nutritional information and ingredients must be on a dedicated digital platform, separate from commercial information about the company and in which users are not tracked in any explicit or implicit way (cookies).
The QR-code that refers to the electronic label must be clearly identifiable and linkable to the relevant information on the physical label.
To direct consumers to the electronic label, it is only possible to use the QR-code which, scanned by the smartphone, opens the URL directly. Printing the web page address (URL) on the label is NOT permitted.
The QR-code must be specific for each individual wine. This means that if the nutritional values change with the change of vintage, for example due to a different alcohol content, or the ingredients due to changes in the production process, it will be necessary to change the QR-code on the label (therefore scrapping the old unused labels). To overcome this problem, but only for nutritional values, the Italian Wine Union is working on a proposal that authorizes the indication of the average values proposed by the European Committee of Wineries (CEEV).
If there are other QR-codes on the label with purposes other than the electronic label, for example for communication, commercial, marketing purposes, etc., they must be positioned in such a way as to avoid any confusion among consumers.
The possibility of authorizing small producers to display the electronic label on their website instead of on an external platform is still under discussion.
In summary, the new community legislation aligns wine with other food and drink products, “forcing” wineries to provide that information transparency on the content of wines that large segments of consumers were requesting.
This is an evolution that could no longer be postponed.
However, it does so by considering the structural specificities of the sector and therefore trying to mitigate the operational complexities for producers.
We will find out next year how the market will actually react to the novelty of knowing wine calories and ingredients, net of research and simulations that seem to suggest a neutral or slightly positive impact.
In the meantime, there is (probably) a year to comply with the new legislation. Be careful: a year passes quickly.