The new European regulation on the labelling of alcoholic beverages: first applications on wines

Apr 28, 2024
Sébastien Bouley

Regulation (EU) 2021/2117 published on 2 December 2021 amends the labelling rules for wines and aromatised wines and makes it mandatory to communicate the list of ingredients and nutrition declaration of those products.

The regulation provides for a transition period of 2 years. For example, the labels of wines produced and labelled after December 8, 2023 must display the list of ingredients and the nutrition declaration from that date.

The new mandatory information to be attached to wine bottles
The nutrition declaration:

In accordance with the Regulation on Consumer Information 1169/2011, it contains the following mandatory information:

  • the energy value expressed in kcal or kJ
  • and the amounts of fats, saturated fatty acids, carbohydrates, sugars, proteins and salt expressed in grams.

The energy value and nutrient content must be presented per 100 ml. Here is an example of how mandatory nutritional information is presented:

Per 100 ml
Energy                             kcal or kJ
Fats g
Including saturated fatty acids g
Carbohydrates g
Including sugars g
Proteins g
Salt g

By way of derogation, it is possible to limit the nutrition declaration on the packaging or on a label attached to it to the energy value, which may be expressed by means of the symbol “E” for “energy”. In this case, the complete nutrition declaration is provided in dematerialized form, electronical form according to the indications on the packaging or on a label attached to it.

The ingredient list:

According to the Consumer Information Regulation (EU) 1169/2011, an ingredient is defined as “any substance or product, including flavourings, food additives and food enzymes, or any component of a compound ingredient, used in the manufacture or preparation of a food and still present in the finished product, possibly in a modified form; residues are not considered ingredients.” The allergen ingredients must be listed in a differentiated manner from other ingredients. Regulation (EU) 2019/934 of 12 March 2019 lists the permitted oenological practices, and their classification as additives or processing aids. Only additives are subject to labelling.

By way of derogation, the list of ingredients may also be provided in dematerialised form, electronically according to the indications on the packaging or on a label attached to it. The list of ingredients starts with the word “contains” followed by the name of the substance or product listed in Annex II to Regulation (EU) No 1169/2011. If the list of ingredients is on an electronic label, it is essential to indicate the presence of allergens on the label itself.

The dematerialization of the new mandatory information must meet certain conditions: it must not be presented with other information intended for sale or marketing; Similarly, do not collect consumer data or be tracked.

Which products are affected?

The labelling of wines “produced and labelled” before 8 December 2023 does not need to be changed and these wines can be placed on the market while stocks last. On the other hand, given the 2-year transition period, wines produced and labelled after December 8, 2023 must include the indication of the list of ingredients and nutritional information.

What about “de-alcoholized” or “partially de-alcoholized wines”?

The new mandatory statements (list of ingredients and nutrition declaration) also apply to “de-alcoholised wines” or “partially de-alcoholised” with an additional statement corresponding to the date of minimum durability. The Best Before Date (BBD) must be presented in the form “best before…” ” or “for an optimal tasting to be enjoyed before (the date of BBD).”

What about alcoholic beverages?

According to Article 16.4 of the INCO Regulation, the list of ingredients and the nutrition declaration are not mandatory on alcoholic beverages with an alcohol content of more than 1.2% by volume. This is a voluntary approach on the part of the operator. In this case, all the requirements relating to the list of ingredients and nutritional information of Regulation 1169/2011 must be complied with.

To conclude, Regulation 2021/2117 makes it mandatory to mention the ingredient list and the nutrition declaration on the labelling of wines from 8 December 2023. The list of ingredients and the nutrition declaration can be presented electronically. In this case, the label shall include the symbol E for “energy” and the energy value in kcal or kJ per 100 ml as well as the allergens as well as a QR code or microchip that refers to the whole information. Wines produced and labelled after December 8, 2023 must comply with these new labeling measures. On the other hand, wines produced and labelled before December 8, 2023 can sell their stock without its mentions.

To find out more, you can consult the European regulations EU 2021/2117. EU 1169/2011.