According to new EU wine labeling regulations, a QR code linked ingredients list must be clearly marked with the word 'Ingredients'. This is outlined in a notice from the European Commission dated November 24 (Official Journal C/2023/1190), which includes questions and answers regarding the amended regulations 1308/2013 and 2019/33 on new wine labeling rules – leading to some seemingly new specifications that are causing dissatisfaction in the wine industry.
The document specifies that mandatory information must be placed "in the same field of vision" on the label. Exceptions are allowed for details like the importer, lot number, or expiration date (the latter for non-alcoholic wines).
The ingredients list must be preceded by a heading that includes the word 'Ingredients'. It must contain all additives and processing aids ('fining agents') that could cause allergies, were used in production, and "are still present in the final product". Yeasts are not included, but concentrated grape must or sucrose for enrichment are. Allergenic substances must be distinguished from other ingredients by a different typeface (e.g., bold).
QR code needs a clear heading
The ingredients list and nutritional declaration can be provided via an e-label/QR code. However, part of the industry's frustration is that it's not sufficient to label the QR code on the label with an 'i' (for information). It states: "The presentation of a QR code should be clear to consumers regarding the content, i.e., the mandatory information presented electronically. General terms or symbols [such as an 'i'] do not meet the requirements of this regulation." Similar to paper labels for other foods, the information [provided via QR code] must have a clear heading [on the label] – specifically with the word 'Ingredients'.
The Comité Européen des Entreprises Vins (CEEV), a European wine business association, contends that the new heading requirement has rendered "many hundreds of millions of already printed labels" obsolete, as the QR codes on these labels are marked only with an 'i'. Consequently, CEEV is calling for a revision of the directive from the EU Commission. This demand for change has reportedly gained support from various EU countries, including major wine producers like France, Italy, and Spain. VM
