Since 8 December 2023, every wine produced has to publish its list of ingredients and its nutrition declaration. Here is what the texts require, obligation by obligation — and what E-Label handles for you.
Who is concerned, and since when?
Every wine produced in the European Union — and every wine imported into it — made after 8 December 2023. Wine produced before that date stays exempt, including stock still being sold off. Most of the information may be provided by electronic means: that is the e-label, reached through a QR code printed on the bottle.
Regulation (EU) 2021/2117
Introduces the list of ingredients and the nutrition declaration for wine, by amending the CMO Regulation (EU) No 1308/2013.
Regulation (EU) No 1169/2011
The food information to consumers baseline: format of the nutrition declaration, allergens, negligible amounts.
Notice C/2023/1190
The Commission’s user manual: the questions and answers that settle the practical cases.
The obligations, point by point.
1
The list of ingredients
Art. 119 of Regulation (EU) No 1308/2013 as amended — C/2023/1190, Q7, Q9 and Q10
It opens with the word “ingredients” and lists them in descending order of weight.
Additives are named by their official functional class: “preservatives and antioxidants: sulphites”, “acidity regulators…”.
Allergens (sulphites, egg, milk and their derivatives) are emphasised inside the list itself, through distinctive typography — bold, in practice.
When the full list is given, a separate “Contains: …” statement must not duplicate it.
With E-Label: The form knows the ingredients used in wine and builds the list in the right order, with the official categories and allergens in bold — in all 24 languages.
2
The nutrition declaration
Annex XV to Regulation (EU) No 1169/2011 — C/2023/1190, Q19
Values are expressed per 100 ml, energy in kJ then kcal, in the order set by Annex XV: energy, fat, saturates, carbohydrate, sugars, protein, salt.
Provided by electronic means, the declaration must keep its tabular format.
On the bottle, you may show the energy value alone, introduced by the symbol “E”.
With E-Label: The regulatory table is generated automatically per 100 ml, kJ before kcal — and the QR code already carries the line “E (100 ML) = … KJ / … KCAL”.
3
Negligible amounts
Art. 34(5) of Regulation (EU) No 1169/2011
Where fat, saturates, carbohydrate, sugars, protein or salt are present in negligible amounts, that row may be replaced by the official statement “Contains negligible amounts of…”, placed in immediate proximity to the table.
With E-Label: The official statement is applied automatically to the nutrients concerned, in the exact wording of each language version of the regulation.
4
The e-label itself
Art. 119(5) of Regulation (EU) No 1308/2013 as amended — C/2023/1190, Q30, Q36, Q37 and Q40
No user data may be collected or tracked: no cookies, no trackers, no identifiable statistics.
The page carries no commercial or marketing content. Even a link to the producer’s own website counts as marketing.
The address must stay valid for the whole life of the product: a printed QR code must never stop answering.
With E-Label: E-Label pages are served with no cookies, no analytics and not one line of marketing; every address is guaranteed for life, even if you change plan.
5
What stays on the physical label
C/2023/1190, Q19 and Q25 — Regulation (EU) No 1169/2011
The energy value stays printed on the bottle (the symbol “E” is allowed).
Allergens stay printed on the label (“contains: sulphites”), even when the full list is online.
Mandatory particulars are printed with an x-height of at least 1.2 mm.
The QR code sits in the same field of vision as the other mandatory particulars.
With E-Label: These duties play out at your printer: your E-Label account repeats them on every page, so nothing is lost between the screen and the bottle.
6
Languages
Art. 121 of Regulation (EU) No 1308/2013 — Regulation (EU) No 1169/2011
Mandatory particulars must be easily understood by consumers in every Member State where the wine is marketed.
A wine sold in several EU countries therefore has to be readable in each of those languages.
With E-Label: A single page serves all 24 official EU languages: the phone’s language is detected automatically, a manual picker is there too, and the wording comes from the official language versions of the regulations.
Who handles what?
E-Label takes care of
The list of ingredients: order, official categories, allergens in bold
The nutrition table per 100 ml, kJ before kcal
The official statement for negligible amounts
All 24 official EU languages
A page with no tracking and no marketing content
The composed QR code (“INGREDIENTS & NUTRITION” + energy value)
An address that stays live for the whole life of the product
You stay responsible for
The accuracy of the ingredients and values you declare
The energy value printed on the bottle
The allergens printed on the physical label
Character size (x-height ≥ 1.2 mm) and where the QR code sits
Keeping page and label consistent at every vintage
Your account repeats these points on every wine, so the printed label keeps up.
This page summarises the texts in force to help you find your way; it is not legal advice. If you have any doubt about a particular case, talk to your control body or your trade association.
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