On November 24, 2023, the European Commission published in the Official Journal (C/2023/1190) clarifications and answers to key questions regarding the new wine labeling regulations. This announcement addresses essential questited to the revised Regulations 1308/2013 and 2019/33 and introduces some notable new requirements.
A key element of the new regulations is the placement of mandatory information. This information must now all be arranged "in the same field of vision" on the wine bottle label. There are some exceptions, for example, for information about the importer, the batch number, or the minimum shelf life date for de-alcoholized wines.
A particular focus is on the ingredient list. It is necessary to have a clear heading with the word "Ingredients" at the beginning. This list must include all additives and processing aids that could trigger allergies, were used in production, and are still present in the finished product. Interestingly, yeasts are not among these substances, while concentrated grape must or sucrose for enrichment must be considered. Allergenic substances must be distinguished from the rest of the ingredients by a different typeface, such as bold print.
Another important aspect concerns the use of QR codes. While the ingredient list and nutritional declaration can be provided via E-Label or QR code, it is no longer sufficient to merely mark the QR code with a general symbol or term, such as an "i" for information. The new regulation requires that QR codes be clearly represented to the consumer in relation to the content – the mandatory information. Consequently, the information provided via QR code on the label must be accompanied by a distinct heading, specifically the word "Ingredients."
It was also reiterated, for which wines the new labeling obligations apply:
In principle, these new mandatory declarations must apply to wines that are marketed from the start date set in Regulation (EU) 2021/2117, i.e., from December 8, 2023. However, wines "produced" before this date can continue to be marketed according to the labeling regulations in force before December 8, 2023, until stocks are depleted.
A wine is considered "produced" in this context if it meets the characteristics and requirements of its wine category.
In short: Still wines whose fermentation is complete fall under the labeling obligations from the 2024 harvest.
Sparkling wines or mulled wines, whose final fermentation or flavoring occurs after December 8, 2023, are already subject to the new labeling obligations.
