Starting on the 8th of December 2023 all wine produced and sold in the European Union will be subject to new labeling requirements. 

As with any sweeping regulatory change, there is bound to be some confusion regarding what needs to happen in order to maintain compliance. In this guide, we’ll be explaining the EU’s new labeling requirements in detail.

What is the EU’s new wine labelling regulation?

Starting on the 8th of December 2023, all wine sold in the European Union that was produced after the effective date of the regulation will need to display a range of nutritional data on the label as per Regulation (EU) 2021/2117

This includes:

  • Allergens
  • Ingredients
  • Energy
  • Other nutritional information

Allergen information will need to be clearly displayed on the physical label. However, you have a bit of freedom with the other information—it can either be displayed on the physical label or disclosed on an e-label accessed via a QR code that’s displayed on the physical label.

The enforcement of this regulation is down to each member state. Failure to comply might mean hefty fines or even having your products removed from the market EU-wide.

FAQs About the EU’s New Wine Label Requirements

Who needs to worry about these new regulations?

First off, there’s no need to worry—complying with these new regulations by the deadline is a relatively simple process. Especially with the right tools…

However, this is a wide-reaching regulation that will affect many groups. To put it simply, any business that sells wine in the EU or produces wine that they want to sell in the EU needs to take the time to understand and comply with these new regulations.

What happens if my wine isn’t compliant?

There’s no simple answer to this question.

There are a range of penalties that can get thrown at you if you fail to comply with these new regulations. The severity will likely depend on the severity of your infraction, along with factors like whether you tried to comply and how long you’ve been in violation.

Penalties could range from a warning letter to fines, temporary selling bans, and even permanent selling bans. Our advice? Don’t test the water and find out—make sure you’re compliant.

What needs to be displayed on the physical label?

As we covered earlier, you need to clearly display allergen and intolerance information on the labels of every wine bottle you sell in the EU.

This includes:

  • Sulfites
  • Gluten
  • Celiac-triggering proteins
  • Milk
  • Eggs
  • Tree nuts

Meeting this requirement means clearly displaying this information on the label itself underneath or beside the word “Contains”. 

What can be displayed on an e-label?

The new regulations give you the option of linking to e-labels via QR codes or URLs displayed on your physical labels. These e-labels can hold a range of information, including both mandatory information and optional information.

For example:

  • Wine type
  • Ingredients
  • Energy (i.e., calories)
  • Country of origin
  • Geographical Indications
  • Vintage year
  • Alcohol by Volume percentage (ABV)
  • Net quantity (ml)
  • Wine sweetness
  • Vine variety
  • Product description
  • Date of expiration

However, there are requirements your e-label will need to meet:

  • No sales or marketing information. Your e-label can’t display any information that’s used for sales or marketing. That means you need to be really careful—creating a webpage for each e-label can be noncompliant if customers can access the rest of your website and its marketing content.
  • No tracking. You’re not allowed to track anything about the customers who access your e-label except for location. This is another major consideration if you want to host e-labels on your main website.
  • Easily accessible. This one's a no-brainer. The QR code needs to be big and high-quality enough to scan. The URL needs to be big enough to read. The information shouldn’t require downloads or multiple clicks to access.

What will I need to create an e-label?

There are really only two tools to create compliant e-labels—a QR generator and a tracker-free e-label hosting service. 

At Marzipan, we’ve combined both of these tools and built Labls. The e-label creation process is incredibly simple: upload the required nutritional information for every wine you sell and we’ll generate both the e-label and the linking QR code. All e-labels are hosted with zero tracking, so you can be sure that your customer’s privacy is always respected.

Why bother with e-labels and QR codes at all?

E-labels are entirely optional. If you want to add all the required information to each physical label, go for it! 

However, there are a bunch of great reasons to think about using e-labels:

  • Branding: As we discuss in our guide to wine branding, your label is extremely important. And text dumps aren’t exactly a great way to communicate your brand.
  • Cost: E-labels allow you to maintain compliance without costly label redesigns. Just update your e-label and you’re good to go.
  • Versatility: You can include a lot more information in an e-label than you would ever be able to fit onto a physical label, like nutrition facts or usage instructions. And since they’re digital, you can make sure that all the information is always up-to-date.
  • Added Value for Non-EU Customers: The same dynamic QR codes that direct EU-based customers to mandatory nutrition information can also be used to direct non-EU-based customers to marketing materials, digital experiences, and (where permitted) special offers.

What language should the labels and e-labels be in?

The language requirements are pretty intuitive—you’ll need to create translations for all 24 official EU languages to make sure they’re accessible to a wide range of customers. Alternatively, you can use a tool like Labls to auto-translate your e-label into any EU language you need.

To make sure customers are receiving a translation they can understand, our e-label tool uses localisation to automatically deliver a translation based on device language settings or location data.

Note: Every EU member state has the option to specify the languages that should be used for nutrition labels. However, since none have exercised this power yet, it’s best to cover all your bases!

Trust Marzipan To Help You Achieve Compliance

The EU’s new labeling regulations will mean changes for wineries and distributors in the EU and around the world. While achieving compliance may not be the most difficult endeavor, it’ll be a whole lot easier with the right tools.

At Marzipan we arm wineries with an all-in-one commerce system designed to centralise your operations into one, easy-to-use platform. In light of these regulatory changes, we’ve created an e-label tool called Labls for creating and managing e-labels and QR codes, ensuring that your labels meet the legal requirements of every market you serve.

You can sign up for a Labls account today and get a free 14 day trial.

Disclaimer: the content in this post is our best understanding of the current state of the EU requirements. You should take your own legal advice to ensure that you are compliant with legislations in the markets in which you sell your wine.

Photo by Guillaume Périgois on Unsplash