February 08, 2024 - 3 comments
Updated on July 19, 2024, according to information published by the European Commission. This article is the result of our interpretation. Do not hesitate to seek legal advice if you need help.
The new European regulation known as (EU) 2021/2117 changes wine labeling rules within the European Union to better inform consumers of what ingredients are in their wine. In concrete terms, all wines sold in the European Union (regardless of where they are produced) will now be required to indicate the list of ingredients and a nutritional declaration.
On paper, this is a revolutionary change for consumers, but it's far more complex than it seems. Let’s take a look at why:
Until now, wine has been exempt from food labelling regulations. Europe put an end to this exception on December 8, 2023 with a new directive, which does indeed stipulate that all wine ingredients must now be displayed, either on the label, on the back label or electronically via a QR Code. The same applies to nutritional declarations. Easy right? Unfortunately not…
What is an ingredient?
This new regulation heavily relies on another one, known as the FIC Regulation (EU legal framework on front-of-pack nutrition labelling), which defines what an ingredient is. And here's where it gets tricky! According to the FIC regulation, food additives are considered ingredients (and must all be listed). But processing aids are not. This seems odd in terms of transparency.
A processing aid is a substance not consumed as a food ingredient per se but used during wine production for a technological purpose. For example, sulfur dioxide is an additive; winemaking yeasts are processing aids. This strange category also includes enzymes, potassium ferrocyanide (a stabilizer), silicon dioxide (a clarifying agent), dimethyldicarbonate (a preservative)... The list is long: among the 82 approved oenological compounds in wine, there are 22 additives and 63 processing aids, some of which cause allergies and intolerances, such as wheat proteins, casein, gelatin, ovalbumin, isinglass, lysozymes...
All additives must be listed, but not processing aids, unless they cause allergies and intolerances and are still present in the finished product. In such cases, it's mandatory to indicate this on the label itself with the mention "contains…", just like with additives.
But that's not all. Some substances can act as both an additive and a processing aid. A simple example: carbon dioxide. If used as a processing aid (carbonic maceration), there's no obligation to list it. But if it's an allergen and present in the finished product, like lysozyme (a protein from egg whites used as a preservative), it must be listed on the label. Still, following? Bravo!
In the end, the ingredient list must include all additives and processing aids causing allergies or intolerances used in the production of the labeled wine and still present in the finished product.
Now, the nutritional declaration
Don't worry, it's simpler. The regulation also mandates displaying this information on two levels:
- The energy value per 100 ml, to indicate the number of calories.
- The complete nutritional declaration, you know, the table found on all food products detailing carbohydrates, fats, etc.
The expected energy value is the “average value”, defined as the value that best represents the quantity of a nutrient contained in a given foodstuff, taking into account possible tolerances. It is expressed in kilojoules (Kj) and kilocalories (kcal), in that order.
Finally, as the regulations apply at the local level in EU countries, some countries may have specific requirements, such as Italy, which requires mentioning the type of materials used (bottle, cap, collar).
How to display all this?
Regulations also govern how this information is displayed.
You can choose to display it on the packaging (not easy) or on the label or back label. In this case, it must be displayed at the same level as the mandatory information, with a character size of at least 1.2 mm. But since it's not always simple to fit everything on a label and keep it readable (especially for those who use many additives), the regulation allows for electronic display via the famous QR Code! But be careful, there are specifics here too!
The ingredient list can be displayed via the QR code, except for ingredients, additives, and processing aids that cause allergies or intolerances and are still present in the finished product. That must be on the label, but not necessarily next to the mandatory information. Fortunately, natural wine producers won't have these constraints! For others, it's a different story.
What about SO2? Well, if you add SO2, or sulfur dioxide, it is an additive and an allergen: it must therefore be listed on both the label as an allergen (contains sulfites) and on the ingredients list. If you do not add SO2, it is not considered an additive, but be careful, wine naturally contains sulfites. Therefore, it must be displayed on the label if the SO2 volume exceeds 10 mg/liter. Otherwise, it is not mandatory.
The energy value must be displayed on the label, using, for example, the symbol "E" followed by the energy value. As for the complete table, which is mandatory, you can display it via the QR code, in the following order: energy, fats (including saturated fats,...); carbohydrates (including sugars,...); proteins, salt.
And the QR code, can we do whatever we want?
No, not really. It must:
- Provide accessible, direct, and universal access to the information;
- Lead to a neutral page without commercial mention, distraction, or commercial links;
- Do not collect any user data.
So, no redirection to your website unless it's a dedicated page free of any other information and links, and even less to your commercial site. The QR code on the label must be specific to the vintage, explicit, and predictive of the nature of the displayed information. Thus, you must display the mention "ingredients" on your label next to the QR code. That's the idea.
When does all this start?
All wines produced after December 8, 2023, are affected.
Specifically:
- For sparkling wines and aperitifs, the regulation applies to products manufactured from December 8, 2023;
- For still and liqueur wines from the 2024 vintage.
Authorities have provided a two-year transition period to be lenient if this information is still missing from labels.
Note:
- Wines "produced" before this date can continue to be marketed until stocks are exhausted;
- Wines not produced in Europe but imported after this date are also affected!
Got it, how do I proceed?
Are you a natural winemaker? Raisin offers a free QR code generator to make your life easier and help you focus on what you do best: producing extraordinary natural wines!
