EU Regulation 2021/2117 creates a significant change for the European Union’s wine and aromatic wine market. As of December 8, 2023, wines bound for the EU market must prominently feature a comprehensive list of all added ingredients on their labels.
Many wineries planned in advance and printed labels to comply with the new regulation, using a QR code and the symbol “i” (for ingredients). However, just a few days before the new regulations would go into effect, the European Commission produced guidelines indicating the QR code would need to be printed with “ingredients” and that the symbol “i” was not sufficient. This provides just two weeks for wineries to shift into compliance with the new guidance. See ‘Hundreds of millions’ of wine labels to be destroyed.
What changes are brought about by the new EU wine regulation?
The new EU wine regulation mandates that all winemakers and distributors in the EU market clearly provide information on labels about:
- Ingredients;
- Allergens and intolerances;
- Energy value; and
- Nutritional values.
Instead of directly printing nutritional information, QR codes will appear on the labels that will allow a consumer to access the above information by scanning the code with a phone. This approach allows winemakers to present sufficient information to the consumer without compromising the overall look and feel of the label design.
These new regulations have prompted the European Committee of Wine Companies (Comité Vins – Ceev) to call for an urgent change to the Guidelines to prevent the destruction of existing wine labels. While the regulation imposes mandatory labeling, it also allows manufacturers to provide the full nutrition declaration and ingredient list electronically, a welcomed move by businesses committed to prompt implementation.
Folks in the industry certainly understand that the timeframe to get a label to print can be significant, especially during busy seasons like the upcoming holiday season. On top of that, the added cost to wineries that need to print (or even re-print) new labels to comply with a last-minute change imposes a considerable burden on wineries that need to make a swift change.
On top of that, if a winery was proactive and already labeled its product in anticipation of the new regulation, it now faces a daunting task of determining the best way to modify an existing label, which could potentially lead to the destruction of numerous pre-printed labels (or determining how to remove said label from a bottle) and impacting their bottom line.
We hope that the European Commission reevaluates its position and allows industry members more time to adjust to this change or at least provides a grace period for any QR codes that may be deemed non-compliant.