Frequently asked questions about the new EU directive for wine labels

In our FAQs, you will find answers to the EU wine labeling regulation (2021/2117). We explain how to best place the QR code on the wine label and how to correctly indicate ingredients and nutritional values.

Legal situation: Legal requirements and content

All wines produced and put into circulation after Dec. 8, 2023 must bear the label.

The following information is mandatory: Nutritional information for 100 ml. Energy content in kj and kcal (this must also be stated on the bottle label). Information on carbohydrates and sugar in grams. Information on fat, unsaturated fatty acids, salt and protein, which can be presented either in tabular form or as text such as 'Contains negligible amounts of fat, saturated fatty acids, protein and salt'. The list of ingredients, consisting of grapes, sulphites and other additives and allergens. Recycling details must also be provided for export to Italy. Additional details such as alcohol content, grape varieties, quality, logos and bottle images are optional.

The legislation applies to wine, sparkling wine, semi-sparkling wine etc. and flavored wine products such as mulled wine and liqueur wines such as port. For mixed wine drinks such as wine spritzers, the general food law applies. These are therefore not affected. Caution: in the case of Austrian "Spritzer", we have heard differing statements from winegrowers. They said that the control authorities had instructed them to state the nutritional information and ingredients here too, as the wine content is 50%. Unfortunately, the information currently differs from country to country.

Here, the winemaker has a choice: either the information on nutritional values and ingredients is printed on the label, or the information is written behind a QR code as a so-called "off-label solution". This means that only the QR code with the heading "Ingredients" and the calorific value have to be printed on the label, which saves a lot of space. The winemaker can choose between the two options.

On the label, in the web store, as well as on catalogs and price lists with ordering options. You must make the information available to consumers wherever consumers can purchase your products. This means on the bottle (for purchase on the store floor), in the web store and on price lists with the option to order.

No. Regulation 2021/2117 states: 'After the date of application of the new labeling rules, existing wine stocks should be allowed to be marketed until exhaustion. Operators should be given sufficient time to adapt to the new labeling rules before they are applied'.

Yes, Regulation 2021/2117 currently only applies to the entire European Union.

The label must be available online for between 3 and 10 years, depending on the quality level. Our service includes a standard period of 10 years, which can be extended on request.

For non-bottled wine produced after 8.12., the same information must be provided as for bottled wine.

In principle, a wine product is deemed to have been produced when it has reached the essential characteristics of its category. In the case of still wine, the time at which alcoholic fermentation is completed is decisive. If fermentation is completed before December 8, the declaration is not yet mandatory. Most 2023 vintages are exempt here. For sparkling wine and semi-sparkling wine, the completion of the second bottle fermentation applies. This means that most 2023 vintages are already affected. For aromatized wines and liqueur wines, the date of final production applies. This means that all products after 08.12.2023 are also affected. However, retailers may need the information on the wines much earlier. They must provide the information on their online store and in their catalogs. It is therefore advisable to create the information for your wines as early as possible. With the e-label.eu software, you can then share all the relevant information with your distributors with just one click. You can find more information in our Master Guide

No. Regulation 2117/21 states: 'Wine that complies with the labelling rules laid down in Article 119 of Regulation (EU) No 1308/2013 and aromatized wine products that comply with the labelling rules laid down in Regulation (EU) No 251/2014, which in both cases apply before 8 December 2023, and which were produced and labelled before that date, may continue to be placed on the market until stocks are exhausted'. Therefore, products placed on the market AFTER December 8th can no longer be labeled with the labels you have in stock.

Yes, Germany is following the corresponding EU Directive 2021/2117, as published by the Federal Government in an answer to a question from the CDU/CSU parliamentary group. https://www.bundestag.de/presse/hib/kurzmeldungen-931546

You can use them for wines whose production is completed BEFORE December 8, 2023. You can also upgrade your old labels using stickers with the words "Ingredients", the printed calorific value and the QR code.

The end of the wine's production process coincides with the date of separation from the lees: This is the date on which it must be reported in the SIAN register as a wine that has been separated from the lees and has therefore completed its production phase; if this coincides with a date after December 8, 2023, the wine must be labeled in accordance with Regulation (EU) 2021/2117.

Yes, if the young wine is still fermenting on December 8, it is not produced; so if you stop fermentation after December 8, it is a wine that falls under the new labeling.

In principle, the producer is responsible for the information on the label. However, if you are the sole bottler on the label and the producer is not named, you are responsible for the information.

For bulk wines produced after 8.12., the same information must be provided as for bottled wines. Of course, non-bottled wine does not have a label, but this is about the labeling regulations: it is about all the information that the producer must provide in the trade and that can be found on the documents with which the non-bottled wine is put into circulation (mvv with QR code on it).

Yes, each vintage is an oenologically new wine and requires its own specifications.

In principle, you must comply with the regulations of the non-EU country to which you are exporting. With the e-label.eu software, we recognize when the e-label is scanned in a non-EU country. You then have the option of either displaying nutritional values and ingredients in English or redirecting the customer to your website.

Language

No, a language commonly used in the EU is sufficient for the heading. Only aromatized wines are an exception. Here, the information on the label must be in the language of the country of sale.

For wine, according to Art. 121 of Regulation (EU) 1308/2013, it is sufficient if the mandatory information is provided in a language of the EU. For aromatised wine products, the obligation applies to provide this information in a 'language easily understood in the country of destination'. There are countries in Europe, such as the Netherlands, that accept the use of English as the standard, i.e. if the manufacturer creates the label and landing page in Italian and English, this is fine. Other countries, such as Italy, do not agree and require that the legal information is always provided in the national language. So if you export to multilingual countries, make sure to translate the content of the landing page. At e-label.eu, the content of the landing page is automatically translated into all 27 EU languages.

QR code on the label

There is no minimum size for the QR code prescribed in the regulation, but it must be practicable; therefore, the definition of the print on the label must ensure its legibility. For a size of 1x1cm, we recommend a quiet zone of 1mm. (see example graphic in the master guide).

The words 'Ingredients and nutritional values' must appear next to the QR code.

There are currently no set guidelines on what QR codes should look like, so you can design yours however you like. However, we recommend making sure that the QR code is easy to read, i.e. large enough and offers a strong contrast from pixel to background.

Yes, the QR code is dynamic and allows you to customize the e-label data and the associated landing page at will and anywhere.

"Dynamic QR codes" allow the content behind the QR code to be adapted at any time, but the printed code remains the same. This gives you complete flexibility. You can print the QR code on the label and subsequently enter the analysis values or make other corrections.

Yes, all wine products containing at least 51% wine are affected by the regulation.

The rule is: one QR code per wine, i.e. per label, and new QR codes for each vintage, which is oenologically a different wine. Regarding the batch: If I always bottle the same wine in different sizes because I have 100 hl and bottle 30 - 30 and 40, there may be slight variations, but certainly not in the ingredients of this wine. So if I don't have to make any variations, then the QR code I use for the first bottling is also good for the subsequent batches. If, on the other hand, the wine changes because I have to work on it, i.e. not only the batch is different but also the wine, then you need a different QR code.

Yes, it is important that the QR code with the nutritional information, the list of ingredients and the information on recycling is correctly labeled with "Ingredients and nutritional information".

Yes, it is important that the QR code with the nutritional information, the list of ingredients and the information on recycling is correctly labeled with "Ingredients and nutritional information".

Yes, we can combine the environmental labeling, nutritional information and ingredient information in one link.

Yes, but it must always be the same wine. Example: Producer X produces TOT. bottles of Rosso Conero, vintage 2024; they all carry the same information and therefore it will always be the same QR code that always leads back to the same landing page. As soon as a characteristic (vintage, grape variety, etc.) changes, it is referred to as a different QR code.

No, a simple printed link is not enough for this. It must be in the form of a QR code.

No. You can write anything on the label as before. The important thing is that there is no marketing element within the landing page and of course there is no user tracking via the QR code.

No. The landing page must not be linked to the winery's website and may only contain: the name, vintage, region and grape variety of the wine, the full nutrition label (list of ingredients and nutritional values) and the recycling information (for the EU countries to which the wine is exported).

No. The QR code must be in the same field of vision as the other mandatory information and must be visible without having to turn the bottle. In other words, if I include everything on the front, I must also place the e-label here (Art. 40 Para. 1 Regulation (EU) 2091/33).

Specifications for the landing page

On the label, I have to store one landing page per wine. Several wines may not be combined here. For catalogs, price lists and the webshop, however, I can combine several wines. Here e-label.eu offers the simple creation of collective QR codes from your already created e-labels.

No. The landing page must not be located within your own company website under any circumstances. It must be a pure page that does not contain any marketing elements.

The name or designation of the wine, so that the landing page can be clearly assigned to the wine that the customer is holding in their hand. This name or designation should appear on the label of the wine.

For the back label of the wine, the website behind the QR code must be specific and individual for this wine. Collective QR codes may only be used for catalogs or price lists.

The languages of the landing page must be those in which the product is sold.

Yes, we can include the company logo/brand name because it helps to identify the wine and the producer we are referring to; however, elements such as phrases, company history, company photo, etc. should not be included.

We do not recommend adding such information to your e-label, as any kind of marketing on the e-label is not allowed. It is also very important that the information on the landing page (e-label) is not duplicated with the information on the printed label.

Yes, but there are several challenges you should consider before hosting your e-label directly on your website. For example, you need to remove user tracking such as cookies used for Google Analytics. In addition, it is crucial to ensure that you are not promoting or selling your wines on the same site to avoid potential fines. Therefore, your e-labels should be hosted separately from your website and online store, as these are considered marketing. Last but not least, you run the risk of losing all your e-labels if changes are made to the structure of your website.

Catalogs, price lists and data sheets

No, these are purely informative and do not require this information.

The following applies to both price lists and catalogs: If the customer can order a wine on the basis of this document, e.g. by telephone or e-mail, the information on the ingredients must also be included there. If it is purely product information and the customer has to go to a store to buy the wine, for example, the information is not required.

Marketing, tracking and penalties

Ingredients and nutritional information are mandatory information, similar to the indication of alcohol content, for example, and the sanctions for violations are therefore the same in perspective as for incorrect alcohol information. However, discussions with several wine inspectors and Dr. Eichele from Rohwedder & Partner have shown that the first phase of implementation will not be too strict as long as it is clear that the regulation has been studied and attempts are being made to implement it correctly.

The lack of digital traceability means that Regulation (EU) 2021/2117 prohibits the manufacturer from collecting information (which could be useful for marketing purposes) about the users who scan the QR code. What is allowed is the approximate determination of the country in which the scan takes place in order to display the language correctly.

No. Comprehensive tracking of users, e.g. using cookies for tools such as Google Analytics, is not permitted. However, an analysis of USE DATA, such as the scan rate or a rough localization of the scans via the IP address, is possible. Together with legal experts, we ensure that our platform is always GDPR-compliant.

Marketing, tracking and penalties

There are EU-wide harmonized tolerances for sugar and carbohydrates. Accordingly, a tolerance of 2 g/100 ml (equivalent to 20 g/l) is permitted for the declaration of sugar/carbohydrates for wines under 10 g per 100 ml (equivalent to 100 g/l, i.e. generally all wines except noble sweet wines). For noble sweet wines with more than 100 g/l sugar, ± 20 % deviations in the indication of carbohydrates/sugar are tolerable. No EU-wide harmonized tolerance is specified for the calorific value. It can be assumed here that deviations in the calorific value of more than 20% or high contents of more than 20 kcal in wines cannot be tolerated.

No. In addition to the alcohol present and the residual sugar, the acidity present is also taken into account. All three details are normally included in the wine analysis.

In principle, the information on nutritional values and ingredients must be provided where it serves to inform the end consumer when making a purchase decision. If a transport document is used when a wine product has already been purchased, it therefore does not have to provide information on nutritional values and ingredients. In this case, it is assumed that consumers have already informed themselves. If you transport a wine product in a tank, but consumers only purchase the wine after it has been bottled, the tank and its transport documents do not have to provide information on nutritional values and ingredients. For non-bottled wine produced after December 8, the same information must be provided as for bottled wine. Of course, non-bottled wine does not have a label, but this is about labeling regulations: it is about all the information that the producer must provide in the trade and that will appear on the documents with which the non-bottled wine is put into circulation (MVV with QR code).

A standard laboratory report with alcohol content, acidity and residual sugar is sufficient. Our e-label software automatically calculates all the necessary values from this, such as the carbohydrates and calorific value.

The exact alcohol content from the laboratory report must be used to calculate the calorific value. Don't worry, this is not explicitly printed, i.e. there is no conflict between the rounded alcohol value on the label and the exact alcohol value in the calorific value calculation; the latter is only included in the calorific value and is not shown.

The total acidity (organic tartaric acid C4H6O6) must be stated here.

Calculation of the carbohydrates: The carbohydrates correspond to the sum of glycerine and residual sugar. The ratio of glycerine to alcohol is 1/10. To calculate the amount of glycerine, the alcohol must be converted into weight: Alcohol volume (ml) to grams (g) -> multiplied by a factor of 0.8 From this follows: Glycerine = [alcohol] * 0.8 / 10. Sugar = [residual sugar] / 10 (calculation per 100ml) Carbohydrates = [sugar] + glycerine Calculation of kcal: 1g alcohol = 7 kcal (30 kJ) 1g sugar = 4 kcal (17 kJ) 1 g organic acid = 4 kcal (17 kJ) 1g extract, glycerine = 4 kcal (17 kJ) 1 kcal = 4.186 kJ This formula was developed together with Dr. Schandelmaier from the DLR (the largest German agricultural and viticultural school), Dr. Eichele from the EU wine law firm Rohwedder & Partner and Prof. Fino from the University of Pollenzo in Italy. The formula is also based on the factor specified in REGULATION (EU) No 1169/2011 for foodstuffs.

Sodium is not normally a common component of wine and is below the minimum value to be indicated.

If you have an official analysis that was carried out at the time the wine was bottled as a basis for calculation, you will not have any problems even if there are some deviations.

Yes, all analyses by an official laboratory are permitted. You only need the values of the alcohol contained, the residual sugar and the total acidity.

Ingredients

According to the EU, only additives that remain in the product must be declared. So-called. processing aids that do not remain in the product do not have to be declared. The EU has published a list of ingredients that must be declared. You can find the complete list here: https://eur-lex.europa.eu/eli/reg_del/2019/934/oj We have transferred this list in full to our software. All ingredients that are on this list must also be declared. If you cannot find a substance on the list, it is a processing aid and does not have to be declared.

The term "grapes" comes first. This is followed by the term "sucrose" in the case of fortification. In the case of enrichment with rectified concentrated grape must or concentrated grape must, the term "concentrated grape must" is inserted. In the case of sparkling wine, the terms "filling dosage" and "shipping dosage" are used. The following ingredients all make up less than 2% of the final product and may be arranged in any order.

Grape must is a natural intermediate product obtained directly from grapes. As follows from Article 48a(1) of Delegated Regulation (EU) 2019/33, the indication of the raw materials constituting the "main ingredient" of the wine may be made by specifying whether grapes and/or grape must have been used or by replacing them all with the single term "grapes". The provision offers a possible simplification for operators, which they can apply on a voluntary basis.

No, bentonite is a processing aid. It does not have to be included in the list of ingredients.

Yes, but you also have the option of simply specifying "grapes" as an ingredient, as must is made from grapes.

These can optionally be used instead of the name of the additive to abbreviate the list of ingredients. However, they are not mandatory under any circumstances.

"Filling dosage" and "shipping dosage" must be stated individually as ingredients. In addition, the ingredients of the doses must be listed individually. Example: List of ingredients: Grapes, sucrose, filling dosage, shipping dosage, Acidity regulators: Tartaric acid Stabilizers: Fumaric acid, metatartaric acid, gum arabic, preservatives and antioxidants: sulphites, L-ascorbic acid

Must may be indicated simply as "must" (without specifying the type; it is therefore not necessary to indicate "partially fermented must", "frozen must", etc.) or simply as "grapes".

The best-before date is not the expiry date: it is only a commercial indication, it is the time after which the producer can no longer guarantee that the characteristics of the wine correspond to those that the consumer can legitimately expect. However, if it is a wine that ages well, it is not a problem to indicate a long shelf life. For wines that are not generic, producers may not make this claim if the specifications do not provide for it. On the other hand, all aromatic/sparkling wines of the genus must indicate the best-before date. The indication of the best-before date on the bottle is obligatory because it helps the consumer to make an informed choice.

Yeast is a processing aid and does not have to be stated in the list of ingredients.

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All packaging gases, regardless of gas, can be specified as "filled under modified atmosphere".

This must be included in the list of ingredients as "carbon dioxide". If the product is subsequently also bottled under CO2, you do NOT have to state "bottled under modified atmosphere" again.

If the analysis values and ingredients are the same, you can use the same QR code.

If the analysis values and ingredients are the same, you can use the same QR code.

Substances that can trigger allergies or intolerances must be listed and highlighted in the list of ingredients. This also applies to allergenic processing aids such as milk and egg. These must be listed at a concentration of more than 0.25 mg/l. Sulphites must be listed at a concentration of more than 10 mg/l and are referred to as "sulphites".

Yes

Software / e-label.eu

All official EU languages can be used to display the e-label details. In addition, our auto-translate function will help you to translate all data quickly.

For label printing, we offer the QR code in the file formats svg, png, jpeg, webp and pdf. You can also download several QR codes at once using our software. The file name is configured according to your requirements to facilitate assignment during printing.

Certainly. You can copy e-label data for similar wines, and we also offer a feature that allows you to upload details in bulk.

You can use your database. I would recommend you take a look at our 'Platinum' package. Here we have a multi-client feature: you can create multiple wine brands under the same account with their respective logo and design. You can also add as many users as you want to your account in case multiple people are working with the tool.

We cannot make individual packages, but we can certainly accommodate you. Our offers should always be fairly priced. Please contact us for an individual offer.

This means that old labels no longer pay off. For example, you produce 30 wines a year and book our silver package. Every year you can now create 30 new e-labels for the new vintage. The old ones don't count, they are still in your software, but they have already been paid for. Therefore, with the annual subscription you only pay for 'new e-labels' and are not pushed into larger packages over time. I hope that answers your question?

You can upgrade a package at any time or downgrade it at the end of the year. If you need more labels and upgrade, you only pay the difference between the two packages and only pro rata for the remaining time. Example: You upgrade from the Silver to the Gold package after 6 months. The difference is EUR 110.00. However, as you only use the larger package for 6 months, you pay 55.00 EUR. After a further 6 months, you then pay for the package you wish to extend.

If you have created an e-label but do not need it, you can delete it on the overview page (three dots at the right-hand end). For us, deleting always means archiving, i.e. a deleted e-label is only archived and can be reactivated at any time. The reason for this is to ensure that e-labels that have already been printed are not accidentally deleted and then cannot be reactivated. Of course, archived e-labels do not count as part of your annual supply of labels. The customer who scans an archived label will see this product as archived. E-labels from the previous year do NOT count towards your current subscription. Please do not delete/archive these e-labels. They are included in your subscription from the previous year and will remain online for 10 years without incurring any further costs.

'Interface' means that each package has a basic interface for importing/exporting data. 'Multimandate' means that you can manage multiple wine brands in the same account.

'Connection to ERP' is a connection to existing ERP or store software solutions where automatic synchronization is required. For this purpose, we offer an API that can be used to synchronize data from your system to us or from our system to your system.

Recycling data

See com. COMM. EU. 24/11. The European Commission prescribes the designation 'Ingredients and nutritional values' next to the QR code with the nutrition label. This also applies if the recycling information is provided here. So nothing needs to be written additionally.

Environmental labeling has been in force in Italy since January 2023.

The QR code / e-label indicating the recycling information should be at least 1 x 1 cm in size.

Sparkling wine / semi-sparkling wine

For sparkling wines, the end of the second fermentation is the relevant date, as a sparkling wine or a Martinotti-Charmat sparkling wine that undergoes secondary fermentation in an autoclave is not produced at the beginning but at the end of fermentation, i.e. when it is separated from the lees. If this date coincides with a date after December 8, 2023, the wine must be labeled in accordance with the regulation.

For sparkling wine, the terms "tirage" and "shipping dosage" are used, either alone or with a list of the actual ingredients. So, a typical sparkling wine contains: grapes, sucrose, tirage, shipping dosage, sulphites, other odds and ends.

There are two ways of indicating the ingredients in sparkling wines. Firstly, you list the wine as an ingredient and indicate the wine's ingredients in brackets. This is followed by the filling dosage and shipping dosage as well as what you add during the second fermentation. Variant 1 "Ingredients: Wine (grapes, sucrose, acidity regulator: E 334), filling dosage, shipping dosage, preservative: sulphites" In the second variant, list all the ingredients of the entire product. Variant 2 "Ingredients: Grapes, sucrose, acidity regulator: E 334, filling dosage, shipping dosage, preservative: sulphites" Both variants are legitimate. Variant 2 is implemented in the e-label.eu software.

Moscato d'Asti

Yes, this must also already comply with the new regulations.

The new EU regulation merely adds ingredients and nutritional information to the previous rules. This means that if you previously had to write the best-before date on the bottle, you now have to do the same. However, the best-before date does not have to be written on the e-label. Only the ingredients, nutritional information and recycling information are included here.
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