New EU Wine Labelling Rules: What Goes on the Label?

New wine labelling rules — what QA teams need to know

Since December 2023, stricter EU requirements for labelling wine and aromatised wine products have been in effect, laid down in Regulation (EU) 2021/2117. Where "Contains sulphites" was previously sufficient, ingredients and nutritional values must now also be declared. This can be done physically on the label or (partially) digitally via a QR code. QA managers and quality professionals in particular face new challenges in practice.

Key obligations:

Ingredient declaration: All ingredients used must be listed, for example "grapes, concentrated grape juice, sulphites". This can go directly on the label or via a QR code.
Nutritional values: The energy value (kJ/kcal) must always appear on the label. The full nutrition declaration (sugar, fats, etc.) may be provided via a QR code.
Allergens: Allergens such as sulphites, egg, milk components and lysozyme must always be shown physically on the label — not only digitally.

Note: The QR code may only lead to mandatory information (no advertising, no cookies).

More info and examples: European Commission — wine labelling.

Practical issues for QA teams — how to tackle them

Many quality managers and QA professionals in the food sector run into new problems in practice now that wine labels need to include more information:

Uncertainty about digital labelling: How do you create a cookie-free QR code with only the mandatory information, without advertising or tracking?
Lack of example labels: Finding clear, correct examples that you can adopt directly is difficult.
Data collection: How do you, as an importer, obtain the correct information from foreign producers, such as ingredients, allergens and full nutritional values?
Allergen declaration: What must go on the label, what may go via QR, and how do you present this clearly for both the consumer and the authorities?
Small labels: How do you fit all mandatory information neatly on a small wine bottle label?
Multilingual requirements: Must everything appear in multiple languages, and does this apply to both the label and the web page behind the QR code?

Practical example 1: Incomplete information from the producer

A small wine importer receives only "grapes, sulphites" from a Spanish producer. Nutritional values are missing. The QA professional cannot complete the label. Solution: Explicitly request a full nutrition declaration. If the producer cannot provide it, commission a laboratory analysis.

Practical example 2: Incorrect allergen declaration

A winemaker places "Contains sulphites, egg, milk" only behind the QR code. During an inspection, a warning follows: allergens must always appear on the physical label, not only digitally. Solution: Always declare allergens physically on the label, for example "Contains: sulphites, egg, milk (allergens)".

Practical example 3: QR code with marketing

A wine brand links its QR code to a product page with advertising and tracking cookies. This is not permitted under the EU rules. Solution: Ensure your QR code leads exclusively to the mandatory ingredient and nutrition information, without advertising or tracking.

Frequently asked questions about the new wine label

Must every wine ingredient now appear on the label?

Yes, since December 2023 all ingredients used must be declared, for example "grapes, concentrated grape juice, sulphites". This can go directly on the label or via a QR code.

Is it mandatory to show the nutritional values of wine?

The energy value (kJ/kcal) is always mandatory on the label. The other nutritional values (such as sugar, fats, carbohydrates) may be provided via a QR code, provided it is easily accessible.

Can I declare allergens only via the QR code?

No, allergens such as sulphites, egg, milk components and lysozyme must always appear physically on the label.

What if my producer cannot supply nutritional values?

As an importer or bottler, you are then obliged to have this analysed yourself. Without this information, you cannot label the product in compliance with the rules.

Can I use the QR code for advertising as well?

No, the QR code may only lead to mandatory information, without marketing, upselling or cookies/tracking.

May I display all information in English?

For wine intended for a specific national market, all mandatory information (on the label and behind the QR code) must be available in the official language(s) of that market.

Useful tips for QA teams on wine labelling

Explicitly ask your producer/importer for the complete ingredient list and nutrition declaration.
Check that allergens always appear physically and clearly on the label (preferably in bold).
Verify your QR code: does it lead directly to a cookie-free, informative page without advertising?
Create a standard format for your wine labels so you do not miss anything.
Keep documentation ready for regulatory inspections.

Want to learn more? See the official overview on the European Commission website.