New EU Wine Label Rules: What Must Be on the Label

The new wine label rules in short

What changed for the wine label?

For a long time, wine sat outside the ordinary labelling rules: of all the mandatory particulars in the food labelling regulation, only the allergen statement ("Contains sulphites") had to appear on the bottle. Regulation (EU) 2021/2117 puts an end to that. Wine and aromatised wine products produced since December 2023 must carry a full ingredient list and a nutrition declaration.

There's also a new digital route. As the first product category to get it, wine may present part of that information through a QR code on the label — the so-called e-label. That saves space on the bottle, but the rules set out precisely what may and may not go digital.

What must always be on the physical label?

Two things can never sit behind a QR code alone:

• The energy value, in kJ and kcal. It must always appear on the physical label.
• All allergens: sulphites, egg and milk products (such as casein used for fining) and lysozyme. Even when the full ingredient list is digital, the allergens stay physically on the bottle.

The mandatory particulars that already applied — alcoholic strength, volume, origin, lot code — don't change.

What can go via the QR code?

The full ingredient list and the full nutrition declaration (sugars, fat, carbohydrates, protein, salt) may be digital, reached through a QR code on the label. Strict conditions apply:

• The QR code leads directly to the mandatory information, with no detours.
• The page carries no advertising or sales functions and sets no cookies or tracking.
• The information is available in the language of the market where the wine is sold, on the label and behind the QR code.

An ordinary product page with an order button therefore won't do. In practice, producers use a separate e-label for this, kept apart from their marketing website.

How do you split it in practice?

Say you import a Spanish rioja. Here's how the split looks:

On the bottle	Behind the QR code
Energy value: 310 kJ / 74 kcal per 100 ml	Full nutrition declaration
"Contains sulphites"	Ingredient list: grapes, concentrated grape must, sulphites
Alcoholic strength, volume, origin, bottler

The ingredient list works exactly as it does for any food: in descending order of weight, with the allergens emphasised. Mind the terminology — it's "concentrated grape must", not "grape juice". Must is the correct oenological term and the one the regulation uses.

What counts as an ingredient — and what doesn't?

The question every winemaker faces when drawing up the list: do all the oenological substances belong in it? The answer comes from the European Commission's Q&A document:

• Additives are ingredients. Preservatives, acidity regulators and other additions belong in the list, stated with their functional category plus name or E-number — for example "preservative: sulphites" or "acidity regulator: tartaric acid".
• Processing aids don't. Fining agents such as bentonite and technical enzymes are not ingredients and stay out of the list.
• Except allergenic processing aids. Casein, lysozyme and egg albumin that remain in the finished product after fining must always be declared as allergens — physically on the label, even though they aren't in the ingredient list.

For your specification that means: record every substance used, and decide for each one whether it's an additive (in the list), a processing aid (not in the list) or an allergenic processing aid (on the label).

Where does it go wrong in practice?

The producer doesn't supply complete data

An importer receives only "grapes, sulphites" from the producer; the nutritional values are missing. Without them you can't finish the label. Ask explicitly for the full ingredient list and nutrition declaration. If the producer won't provide it, there's no way around commissioning a laboratory analysis yourself — as the importer or bottler, that responsibility is yours.

Allergens only behind the QR code

A winemaker puts "Contains sulphites, egg, milk" on the e-label alone. At an inspection by the competent authority (in the Netherlands the NVWA) that earns a warning: allergens always belong on the physical label. Put them on the bottle, clearly emphasised.

The QR code leads to marketing

A wine brand points its QR code at a product page with advertising and tracking cookies. That isn't allowed. Check every QR code on the shelf: does it lead directly to a clean page with only the mandatory information?

Frequently asked questions about the wine label

Does every wine ingredient have to be on the label?

Yes. Since December 2023 all ingredients used must be listed, for example "grapes, concentrated grape must, sulphites". This can go on the label itself or via the QR code.

Is the nutrition declaration mandatory for wine?

The energy value (kJ/kcal) must always be on the physical label. The full nutrition declaration may go via the QR code, provided it's easily accessible.

Can I declare allergens only via the QR code?

No. Sulphites, egg and milk products and lysozyme must always appear physically on the label.

What if my producer can't supply nutritional values?

Then, as the importer or bottler, you're required to determine them yourself, for example through a laboratory analysis. Without that data you can't label the product in line with the rules.

May the QR code also lead to advertising?

No. The QR code may lead only to the mandatory information, with no marketing, sales functions, cookies or tracking.

May all the information be in English?

The mandatory information must be available in the language of the market where the wine is sold, both on the label and behind the QR code — so not automatically in English.

Do fining agents have to be on the label?

No, processing aids such as bentonite don't belong in the ingredient list. The exception: allergenic processing aids (casein, lysozyme, egg albumin) that remain in the finished product must always appear as allergens on the physical label.

Can I still use up my old labels?

Wine produced before 8 December 2023 may be sold with the old label until stocks run out. Anything produced after that date must meet the new rules.

From specification to wine label

The new rules turn wine into an ordinary food: the ingredient list has to match the production process, the allergens have to match the substances used, and the nutritional values have to match the analysis. That's exactly the work Eclarion is built for. You record the composition once in the specification — grapes, must, additives and processing aids — and from that you generate the ingredient declaration, the allergen statement and the nutrition declaration. The data that belongs behind your QR code comes from the same source too, in whatever language your market asks for. Start a free trial and get your first wine label right.

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