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Legal2 min read

Wine E-Label: Which details must be on the label and which can go in the QR code

With EU Regulation 2021/2117, wine has lost its special status: Since 8 December 2023, newly produced wines require an ingredient list and a nutritional declaration, as do aromatized wine products. Crucially, the regulation explicitly allows for some of this information to be provided electronically. The question is no longer whether, but where each piece of information should appear.

The breakdown at a glance

InformationOn the labelOn the e-label
Allergens (e.g. sulphites, egg, milk)Mandatory, with "Contains"Additionally, highlighted in the ingredient list
Energy value (kJ / kcal per 100 ml)Mandatory, may be abbreviated with "E"Yes, in the nutritional table
Other nutritional valuesNo, if the e-label shows themYes
Ingredient listNo, if the e-label shows itYes
Classic information (alcohol, origin, bottler, net volume ...)Mandatory as beforeNo, must be on the label
Simplified overview based on Regulation (EU) 2021/2117 and the EU Commission's announcement from November 2023. Not legal advice — the guidance from the relevant control authority is decisive.

The ingredient list

Ingredients are listed in descending order of their weight. "Grapes" usually appears at the beginning. Additives are named by their class, for example "Acid regulator: Tartaric acid" or "Preservative: Sulphites". For certain cases, collective terms are used, such as for protective gases. Allergens must be highlighted in the text, for example in bold — on a well-designed e-label page, this happens automatically.

The nutritional table

Values per 100 ml must be stated: Energy in kJ and kcal, Fat, of which saturated fatty acids, Carbohydrates, of which sugars, Protein and Salt. Because fat, protein and salt are practically non-existent in wine, food law allows the statement "Contains negligible amounts of fat, saturated fats, protein and salt". This is what appears on most e-labels.

What the e-label must not do

  • No sales or promotional content on the same page — no shop, no promotions
  • No collection or analysis of user data
  • No registration or forms before the information is visible
  • No redirecting to a general homepage where the information must first be searched for

Labelling next to the code

Anyone scanning the code must be able to see that ingredients and nutritional values are behind it. According to the Commission's interpretation, a simple "i" is not sufficient; the word "Ingredients" or "Ingredients & Nutrition" in the language of the country of sale is standard. Because member state authorities handle this differently, it is worth asking your winegrowers' association for a quick clarification before printing.

And wines before December 2023?

Wines produced before 8 December 2023 may be sold without ingredient and nutritional information until existing stocks are exhausted. The production date is decisive, not the bottling date.

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Frequently asked questions

Must the energy value always be on the label?

Yes. Even if the full nutritional table is on the e-label, the energy value must be on the label. The abbreviation "E" is allowed.

Does the requirement also apply to sparkling wine?

Yes, it applies to the wine products of the Common Market Organisation, so also to sparkling wine, semi-sparkling wine and fortified wine, as well as to aromatized wine products.

In which language must the e-label be?

In the language or languages of the country where the wine is sold. Exporters need corresponding multiple language versions.

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