Prior to 6 December 2021, under the Food Information to Consumers Regulation (Regulation (EU) 1169/2011), alcoholic beverages containing more than 1.2 percent of alcohol by volume were exempted from the obligation to list a nutrition declaration and a list of ingredients.
The above was amended by the publication of Regulation (EU) 2021/2117 on 6 December 2021 in the EU’s Official Journal. Regulation (EU) 2021/2117 along with, two other Regulations that make up the EU’s Common Agricultural Policy (CAP).
As provided for under Regulation (EU) 2021/2117 as of 8 December 2023, it will be compulsory for all wine products sold in the EU market to list nutrition declaration and list of ingredients.
Mandatory information per Regulation 1169/2011, shall appear in a language easily understood by the consumers of the Member States where a food is marketed.
The full nutrition declaration and ingredients list may be listed on the physical label provided that any allergens are listed, and must be indicated and emphasised through a typeset that clearly distinguishes it from the rest of the ingredients.
The list of ingredients shall be headed or preceded by a suitable heading that consists of or includes the word ingredients. It shall include all the ingredients of the wine, in descending order of weight.
Regulation 2021/2117 gives producers the option of having the full nutrition declaration on the physical label or only listing the energy value ((100 ml) E = xxx KJ / xxx Kcal), which may be expressed by using the symbol “E” for energy. In the latter case, the full nutrition declaration and ingredients list shall be provided by electronic means identified on the package or on a label attached thereto (e.g., via a QR code).
There are three limitations to this option(QR code option):
- Ingredients causing allergies and intolerances must be on the “physical” label; (e.g.,
contains sulphites, contains egg albumin, contains milk casein) - “Electronic” labels/ QR codes cannot contain any other information intended for
sales or marketing purposes; and - No user data can be collected or tracked through electronic means.
Nutritional information
The nutrition declaration is provided per 100ml.
Per Article 31(4) of EU Regulation 1169/2011, the declared values shall according to the product be the average values based on – the manufacturer’s analysis of the food (wine is defined as a food product in the EU) or a calculation from the known or actual average values of the ingredients used or a calculation from generally established and accepted data.
To calculate the energy value for wine, Carbohydrates (sugar), Polyols (glycerol predominately, the other polyols, D-mannitol, D-arabitol, etc won’t have a significant effect on energy value), alcohol (actual not label), organic acids, erythritol (only naturally occurring in wine) The conversion factors listed in Annex XIV of EU Regulation 1169/2011 can be used to calculate the energy value.
The other values listed below (protein, fats, salatrims, and fibre) are rarely present in significant values in wine and will thus not make significant contributions to energy content.
Example of nutrient declaration. Important to note: 1 calorie = 4.1840 J.
Mandatory list of ingredients
Only wine additives as defined in Commission Delegated Regulation (EU) 2019/934 shall be included in the list of ingredients.
Additives must be designated by the name of the category they belong to, followed by their specific name or E number. E.g., Acidity regulator (Malic acid)/ Acidity regulator (E296).
The term grapes should replace the terms must and a fermented must when used before fermentation.
The term grape must shall be used instead of the term concentrated grape must when used as a sweetener or for enrichment.
The term grape must shall be used instead of the term grape must in fermentation and concentrated grape must when used in the tirage liqueur or the expedition liqueur.
Argon, Nitrogen, and Carbon dioxide must be indicated in the list of ingredients only when they are used as packaging gases per point 20 of Annex I to Regulation (EC) No 1333/2008 of the European Parliament and of the Council of 16 December 2008 on food additives.
When Carbon dioxide is used for aerated sparkling wines and aerated semi-sparkling wines (perle wines), it should not be considered as an additive but as an ingredient per se and thus should be indicated as such without the indication of a category of additive thus not listed as Packaging gas (Carbon dioxide) but simply as Carbon dioxide.
Added yeast and bacteria are considered processing aids and shall not be included in the list of ingredients.
Processing aids will be included only if their use results in the presence of substances causing allergies or intolerances. (e.g., Casein and Egg Albumin)
The physical label must list substances causing allergies or intolerances even if the rest of the ingredients are only listed on the electronic label/QR code. The allergens must be indicated and emphasised through a typeset that clearly distinguishes it from the rest of the ingredients of the list, for example by means of the font, style, or background colour.
Where several ingredients of a product originate from a single substance causing allergies or intolerances, the labelling shall make it clear for each ingredient concerned. When the presence of a substance causing allergies or intolerance derivates from the use of a processing aid, it should be indicated in the list of ingredients.
