Article
New rules for wine labelling
From 8 December 2023, following Regulation (EU) 2021/2117, wine and aromatised-wine labels must include ingredient information and nutrition information, subject to the transitional regime for bottles produced and labelled before that date.
This English version follows the Portuguese VinumLex original and is presented here for informative reading. The Portuguese original remains the reference source for archival purposes.
What changed at EU level
The reform requires ingredient lists and nutrition information for wines and aromatised wines. Bottles produced and labelled before 8 December 2023 remain unaffected and may continue to be marketed until existing stocks are exhausted.
The first legal question is definitional: what counts as an ingredient? Under Regulation (EU) No. 1169/2011, an ingredient includes any substance or product used in the manufacture or preparation of the food and still present in the finished product, even in modified form, while a residue is not treated as an ingredient.
Which oenological substances matter on the label
Regulation (EU) 2019/934 lists the authorised oenological practices and classifies substances either as additives or as processing aids. Only additives must appear in the ingredient list, except that certain allergens must also be disclosed even if treated technically as processing aids.
The practical categories most often discussed are acidity regulators, preservatives and antioxidants, stabilisers and allergens such as ovalbumin and caseinate.
- Acidity regulators may include tartaric, malic or citric acid and calcium sulphate.
- Preservatives and antioxidants include sulphur dioxide, potassium metabisulphite, lysozyme, sorbate and dimethyl dicarbonate.
- Stabilisers include gum arabic, metatartaric acid, potassium polyaspartate and carboxymethylcellulose.
Nutrition declaration and digital access
For wine, the on-label nutrition declaration may be limited to energy value, provided that the full nutrition information is made fully accessible by electronic means. The sector has therefore moved towards QR codes placed on the bottle or on the back label.
This solution attempts to reconcile transparency with label design, allowing the consumer to access the relevant information in a simple way without overloading the physical label.
Why the reform matters
The reform reflects concerns of public health, transparency and convergence with information duties long established in other food sectors.
At the same time, it generates new costs for producers, who must redesign labels, implement QR systems and coordinate legal, technical and marketing teams. Distributors and sales staff also need to understand the logic of the disclosed ingredients and nutrition data.