Legal information note — changes to the labelling of wine products

Executive summary

The 2024 Ordinance strengthens the clarity and precision of mandatory particulars and places greater responsibility on economic operators, because the SIVV model continues to be based on mere submission of labels rather than prior administrative approval.

As a result, compliance risk moves even more decisively to ex post inspection, with practical consequences that may include administrative offences, seizure of products and destruction of non-compliant labels or lots.

Legal framework

The relevant normative sequence is formed by Ordinance No. 314/2024/1, the official rectification confirming the minimum sizes in millimetres, and Ordinance No. 312/2022, which had already introduced the SIVV notification regime and the obligation to make labels publicly available.

Read together, these acts show a broader trend: dematerialisation of prior control, coupled with stronger ex post monitoring.

Legally significant amendments

The most important changes concern the indication of provenance, the clarification of competences in the Autonomous Regions, the recognition of additional traditional designations and the admission of “late harvest” under tightly defined conditions.

The republished consolidated text also has practical value in itself, because it reduces interpretative fragmentation and facilitates legal audits and internal compliance review.

• Provenance wording is now framed by closed formulas and minimum character sizes.
• The anti-misleading clause is strengthened.
• Additional designations such as “clarete”, “jeropiga” and “mass wine” are expressly accommodated where the legal conditions are met.
• The late-harvest mention is reserved to PDO/PGI wines meeting technical overripeness requirements.

Legal risk and sanctions

Failure to comply with the new labelling regime may expose producers, bottlers, distributors and traders to serious or very serious administrative offences, with financial and reputational consequences.

The relevant risk is not merely formal. A label can be unlawful not only because the wording or type size is wrong, but also because it creates a misleading impression regarding origin, category or characteristics of the wine.

Practical recommendations

From a compliance perspective, labels should be reviewed legally before SIVV submission, character size should be tested graphically, and marketing and design teams should be trained in the anti-misleading clause and in the permitted expressions.

Operators should also plan the run-out of old stocks in line with the wine-campaign calendar and maintain continuous legal monitoring, since prior administrative screening no longer acts as a protective filter.