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Label Management
Published:
October 30, 2023
Updated:
November 27, 2023

Old Wine in a New Label: Understanding EU's New Label Requirements.

Rangan Das

Old Wine in a New Label: Understanding EU's New Label Requirements.

Published:
October 3, 2023
Updated:
November 27, 2023
Rangan Das

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If you're a wine enthusiast, you're probably well aware that a bottle of wine contains more than just crushed grapes. However, it's a curious fact that you won't typically find a list of those "secret" ingredients or the wine's nutritional facts on the label. This has been the historical norm, both in the United States (governed by the FDA) and the European Union (E.U.), where wine labels were only obliged to mention allergens.

But wait, there's a twist in the tale! In the E.U., there are winds of change blowing through the vineyards. New EU label regulations are set to uncork a whole new world of information on wine labels, starting from December 8, 2023. This transformation will redefine how wineries, distributors, and label producers showcase their products to the discerning European consumer.

Here, we go over the specifics of these regulations, figuring out where we are now and what this could mean for the wine industry across Europe, and how a creative ops solution can help.

Understanding the EU's New Label Requirements

The new wine label requirements, slated to come into effect on December 8, 2023, represent a pivotal shift in the way wine is presented and marketed in this vast and diverse market. These product labeling guidelines are a response to the changing landscape of consumer expectations and a desire for greater transparency regarding what goes into that bottle of wine. 

Here are the key focus areas for the new labeling requirements. 

Transparency and empowerment

The new EU packaging regulations are driven by a dual purpose: to enhance transparency and empower consumers. In essence, they aim to provide consumers with a comprehensive understanding of the wines they are purchasing. This newfound transparency will extend to both the composition and nutritional aspects of the wine, giving consumers a more informed choice when selecting their preferred bottle.

A complete list of ingredients

A significant departure from the past is the requirement to disclose ingredients. While wines are primarily made from grapes, many winemakers use additives and processing aids during production. These could range from harmless compounds like tartaric acid to potential allergens such as egg whites or milk proteins. The new regulations mandate that these ingredients be listed on the label or made available through electronic means like QR codes.

Nutritional information

Just like food products, wines will now be required to display nutritional information. This includes details on energy content and other key nutritional factors. For consumers conscious of their dietary choices, this information can be invaluable.

Electronic means of disclosure

A notable feature of the new regulations is the allowance for electronic means of disclosure. This opens the door to innovation, as winemakers can provide detailed information through QR codes or web links. This not only ensures compliance but also allows for a more extensive presentation of information without cluttering the label. Manufacturers may eventually also adopt smarter technologies like labels with embedded NFC tags that can act as an electronic means of disclosure.

Understanding these regulations is crucial for wineries, distributors, and label producers. Compliance is not just about following the letter of the law; it's also about meeting consumer expectations. Those who adapt and embrace these changes are likely to gain an edge in an increasingly competitive market.

Also read: How Artwork Flow Helps in Label Approval and Compliance Management Process

What are the requirements for labels in the EU?

Source: Casalonga

Prior to 2023, the EU's wine labeling was last updated in 2000, which was Regulation (EC) No 1493/1999. It was adopted by the European Parliament and the Council of the European Union on May 17, 1999, and it came into effect on December 31, 2000. These regulations, which are how wine labels are made today, had the following requirements:

  1. Name of the wine: The label must prominently display the name of the wine clearly and legibly. This name must align with the type of wine it represents and must not mislead consumers.
  2. Grape variety(ies): In the case of varietal wines, the label must list the grape variety(ies) used to make the wine. These varieties should be listed in descending order of importance, providing consumers with insights into the composition of wine.
  3. Region of origin (PDO or PGI): If the wine bears a protected designation of origin (PDO) or protected geographical indication (PGI), the label must specify the name of the region where the wine was produced. This geographical information adds an extra layer of authenticity to the wine.
  4. Alcohol content by volume (ABV): The label must include the alcohol content by volume (ABV) of the wine, expressed as a percentage. This detail helps consumers gauge the strength of the wine.
  5. Name and address of the producer or importer: The label must feature the name and address of the wine producer or importer. This information ensures traceability and accountability within the wine supply chain.
  6. Additional information: While not mandatory, labels may include supplementary information such as the vintage year, wine type, color, and any awards or distinctions the wine has received. However, any extra information mustn't mislead consumers.
  7. Language: Labels must be written in a language easily understood by consumers in the country where the wine is sold. If the wine is marketed in multiple countries, the label must be in the official language(s) of each respective country, 
  8. Clarity and affixing: The label must be clear and legible, ensuring that consumers can easily read the provided information. Additionally, it should be affixed to the wine bottle securely to prevent easy removal.
  9. Specific rules for sparkling and fortified Wines: The 1999 regulation introduced specific rules for labeling sparkling and fortified wines.

The 1999 regulations were not as comprehensive as the 2023 regulations. They did not require wine producers to list all ingredients used in the wine, nor did they require them to list nutritional information. However, they were a significant step forward in terms of consumer transparency, and they helped to protect consumers from allergic reactions and other health problems.

Also read: How to Make Sure Your Labels Are Compliant with the EU MDR and IVDR In 2023

Key changes in EU labeling regulations

The EU label design guidelines introduce significant changes that will ripple through the wine industry. After December 8, 2023, all wines produced after this date must adhere to the disclosure requirements outlined in Regulation (EU) 2021/2117

Also read: What is Label Design Proofing & How to Manage it Remotely

This includes providing information on ingredients, allergens, energy, and nutrition. Here are the different regulatory points in more detail:

  • Format: The new wine labels must be formatted in a standardized way, making it easier for consumers to compare wines. The label must include the following information in a specific order:
  1. The name of the wine
  2. The grape varieties used if the wine is labeled as a varietal wine.
  3. The region of origin, if the wine is labeled with a protected designation of origin (PDO) or protected geographical indication (PGI).
  4. The alcohol content by volume (ABV).
  5. The name and address of the producer or importer.
  6. The ingredients.
  7. The complete nutritional information.
  8. Any other required information, such as the vintage year or the type of wine.

  • Energy information: One of the key requirements for wine labels in the European Union is the inclusion of energy information. This is akin to the calorie declaration found on food products in the United States. The energy value must be displayed using the symbol "E" and should be based on a standard serving size of 100. This information allows consumers to gauge the caloric content of the wine they are consuming, contributing to their understanding of its nutritional profile.
  • Designation of category: Wine labels must indicate the category or type of wine they represent. This helps consumers quickly identify whether they are looking at red, white, sparkling, or other types of wine. This information is fundamental in guiding consumer choices based on personal preferences.
  • Intolerances and allergens: The label should provide information about any intolerances and allergens present in wine. This is a critical requirement for individuals with specific dietary restrictions or allergies. Utilizing label management ensures that by listing allergens, such as milk proteins or egg whites, consumers can make informed choices about whether the wine aligns with their dietary needs.
  • Actual alcoholic strength by volume: The alcohol content of the wine must be clearly stated on the label. This informs consumers about the strength of the wine they are consuming. It's not only useful for those who want to monitor their alcohol intake but also for those who prefer wines with specific alcohol content.
  • Indication of provenance: Wine labels should indicate the provenance or origin of the wine. This information provides consumers with insights into the geographical region where the grapes were grown, and the wine was produced. For many wine enthusiasts, the origin of a wine can be a significant factor in their purchasing decision.
  • Lot number: Each bottle of wine should bear a lot number. This is crucial for quality control and traceability, especially in the event of recalls or quality-related issues.
  • Net quantity: The label must clearly state the net quantity of the wine within the bottle. This ensures that consumers know exactly how much wine they are purchasing.

Product-specific labeling rules

For de-alcoholized wine, sparking wine, and imported wines, the New EU label guidelines have an additional set of regulations. 

De-alcoholized wines

Wines that have undergone a process to reduce their alcoholic content, often referred to as "de-alcoholized" wines, are subject to the same labeling regulations as regular alcoholic wines within the EU. However, there are distinct requirements based on the amount of alcohol retained in the beverage after the de-alcoholization process.

  • Label terminology: To accurately convey the nature of the wine, the term "de-alcoholized" (U.K. spelling) must be included on the wine label. This term informs consumers that the wine has undergone a process to reduce its alcohol content. Importantly, this terminology must be used regardless of the amount of alcohol remaining in the wine.
  • Alcohol content thresholds: The regulations introduce specific thresholds based on the remaining alcohol content:
  • Alcohol content of no more than 0.5%: If the wine's alcohol content by volume after the de-alcoholization process is no more than 0.5%, the term "de-alcoholized" must be included on the label. This designation indicates that wine has undergone a substantial reduction in alcohol content.
  • Alcohol content more than 0.5% but below category minimum: If the wine retains more than 0.5% alcohol by volume but falls below the minimum alcoholic strength required for its category before de-alcoholization, it can be labeled as "partially de-alcoholized." This label clarifies that the wine has undergone a reduction in alcohol content but still maintains some degree of alcohol.
  • Date of minimum durability: An important distinction in labeling relates to the date of minimum durability. For wines with an alcohol content by volume of less than 10%, it is mandatory to include the date of minimum durability on the physical label. This date signifies the period during which the wine is expected to maintain its quality. Additionally, this information may also be provided through electronic means, further aligning with the trend of using digital resources for comprehensive wine labeling.

Sparkling wines

  • Label terminology: Sparkling wines must be labeled with the words "sparkling wine" or "crémant". They must also be labeled with the name of the region where they were produced, as well as the grape variety(ies) used.
  • Bottler or producer/vendor: The label should specify the name of the bottler or producer/vendor. This adds an extra layer of transparency by revealing who handled the wine's final packaging, particularly important in the case of sparkling wines.
  • Sugar content: For sparkling wines, the label should include information about the sugar content. This is relevant as it can indicate the sweetness level of the sparkling wine, helping consumers choose wines that align with their taste preferences.

Fortified wines

  • Label terminology: Fortified wines must be labeled with the words "fortified wine" or "liqueur wine". They must also be labeled with the alcohol content by volume (ABV).

Imported wines

  • Importer: Imported wines must include information about the importer. This allows consumers to identify who brought the wine into the EU market. It's crucial for traceability and accountability in the event of issues or questions about wine.

Also read: FDA 2023 Labeling Regulations Guide For Non-alcoholic Beverages

This level of transparency allows consumers to make informed decisions while also building trust within the wine industry. However, accommodating this wealth of information while maintaining the label's visual appeal and branding presents challenges for label design. Brands can opt for dedicated brand asset management software to help them navigate these complex compliance issues.

Here’s the summary of the new changes:

Comparison of old and new regulations of wine labels

Conclusion

In conclusion, the EU's new wine label requirements set the stage for a transformation in how wine is presented to consumers. Embracing these changes can be challenging, but it also presents opportunities for innovation and adaptation. Redesigning labels can often be challenging and requires a collaborative effort from all the stakeholders. However, with the right creative ops management tool, creating new compliant designs can be effortless. To see how a creative ops platform can help, check out Artwork Flow

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