New EU wine label - background and examples
The EU Regulation 2021/2117 brings with it adaptations in the wine declaration that are equivalent to the previously applicable regulations for food. The list of ingredients and a nutrition declaration are newly added as mandatory information. These provisions come into force on 8 December 2023. Usually, new requirements for products already filled, labelled and on the market are accompanied by sales regulations. In this case, however, these have not yet been set.
The obligation to provide a list of ingredients and a nutrition declaration has already existed for food for some time. The Food Information Regulation (LMIV) aims to provide consumers with comprehensive information when purchasing food and to offer manufacturers uniform and clear specifications for labelling and designation within the European internal market.
The effects of the regulation also extend to price lists and online shops.
General advertising materials that do not lead to a purchase decision or do not offer an immediate ordering option are exempt from these requirements.
e-Label
The requirements for an E-Label
Through an "e-label", the comprehensive nutritional information and ingredient list can be electronically displayed.
In the context of an e-label, the caloric content and allergen details must also be present on the wine label.
In the scenario of an e-label, the allergen information can also be provided outside the immediate field of required information.
An e-label consists of a QR code positioned on the wine label. This code can be scanned using a smartphone, leading to a corresponding website (file hosting service) where the relevant data is stored.
PLEASE NOTE:
The collection or tracking of user data and the dissemination of information for marketing purposes are strictly prohibited with an e-label.
The e-label should be maintained for the duration of the wine's availability for sale.
While no minimum size is specified for the QR code, it is generally recommended to ensure a QR code size of at least 1 x 1 cm for optimal readability.
Nutrition declaration
The nutritional declaration encompasses details regarding energy content, fat content, saturated fat content, carbohydrates, sugars, proteins, and salt.
A tabular format is mandated, wherein the information pertains to a volume of 100 ml.
Wine bottles consistently offer ample space for a suitably sized label, facilitating the placement of a table in the specified font size; the same principle assuredly applies to websites. In instances where space is constrained, such as in printed media (such as price lists), the information can be presented sequentially.
In wine, the quantities of fat, saturated fatty acids, proteins, and salt are exceedingly minimal. Consequently, no analysis is provided for these values.
As per the EU guidelines on nutrition labelling, the statement "Contains negligible amounts of fat, saturated fatty acids, proteins, and salt" below the table is sufficient.
Carbohydrates, sugar and calorific value
According to the Food Regulation, the values of a nutritional table can be based on a food analysis.
The carbohydrates contained in wine are mainly composed of the sugars, glucose and fructose.
In wine, the proportion of polysaccharides is so low that the quantities indicated for carbohydrates and sugars are the same.
This principle has already been applied to grape juice. The carbohydrate and sugar content per 100 ml can be indicated either to the nearest 1 g or more precisely to the nearest 0.1 g with decimal point.
Nutrition labelling
the requirements for nutrition labelling
A nutrition label must contain the following information.
The order shall be followed and the units mentioned shall be used.
The information must be given in tabular form, with the numbers below each other.
The nutritional information always refers to 100 ml.
In wine, the amounts of fat, saturated fatty acids, protein and salt may be declared as a minor amount where appropriate. Since no salt is added to wine, a claim stating that the salt content is due solely to the presence of naturally occurring sodium may appear in close proximity to the nutrition declaration.
In addition to the nutrition table, the energy content and amounts of fat, saturated fat, sugars and salt may also be indicated.
saturated fatty acids, sugars and salt may also be repeated on the front. The information may be given here per portion, but the calorific value must also be given per 100 ml.
Example of a nutrition table for wine. A value is given for all parameters; voluntary reference to salt content.
| Nutritional information | je 100ml |
| Calorific value | 349 kJ / 82 kcal |
| Fat | 0,01 g |
| thereof saturated fatty acids | 0,002 g |
| Carbohydrates | 1,7g |
| thereof sugar | 1,7g |
| Protein | 0,02g |
| Salt | 0,008 g* |
List of ingredients
A "food additive" is a substance, with or without nutritional value, which is not normally consumed as a food itself or used as a characteristic food ingredient, and which is added to a food for technological reasons during its manufacture, processing, preparation, treatment, packaging, transport or storage, as a result of which it or its by-products become or may become directly or indirectly a component of the food.
Food additives are listed in the list of ingredients
A list of ingredients is only necessary if several ingredients are used; if wine is the only ingredient, no list of ingredients is required.
As an alternative to their name, additives may also be indicated with their E-number.
The list of ingredients must be preceded by a heading or a suitable designation in which the word "ingredients" appears. The simplest way is to prefix the list of ingredients with the word "ingredients" or "list of ingredients". This is followed by the ingredients of the wine used to make it.
The order is descending, ordered by the quantity of ingredients used. The word "grapes" shall come first.
This is followed by the term "sucrose" in the case of fortification. In the case of enrichment with rectified grape must
In the case of enrichment with rectified concentrated grape must or concentrated grape must, the term "concentrated grape must" shall be inserted. For sparkling wine, the terms 'tirage liqueur' and 'expedition liqueur' shall be used, either alone or with a list of actual ingredients in accordance with EU Regulation 2019 /934 Annex II.
Ingredients with a quantitative share of less than two percent may be listed in any order. A concrete indication of quantity in percent, according to the so-called Quid rule, is necessary for ingredients that are highlighted by words or illustrations on the packaging of the food.
The quantity labelling rule QUID (Quantitative Ingredient Declaration) stipulates that value- and flavour-giving ingredients that are mentioned in the name of the food or highlighted by illustrations must be stated with their percentage share in the list of ingredients.
List of ingredients
- always the first ingredient is "grapes"
- in the case of enrichment, the second ingredient shall be "sucrose"
- in the case of enrichment with rectified concentrated grape must or concentrated grape must, the term "concentrated grape must" is inserted.
- in the case of sparkling wine production, "tirage liqueur" and "expedition liqueur" are listed
oenological additives
(complete list in EU Regulation 2019/93
Acidity regulators::
- Tartaric acid (L+), E334
- Malic acid, E296
- Lactic acid, E270
- Calcium sulphate, 516
- Citric acid, E330
- If more than one, also X "and/or" Y "and/or" Z
Stabilisers:
- Tartaric acid (L+), E334
- Malic acid, E296
- Lactic acid, E270
- Calcium sulphate, 516
- Citric acid, E330
- If more than one, also X "and/or" Y "and/or" Z
Gases and packing gases - simultaneously with this into the corresponding
filled into the corresponding container:
- Argon, E938
- Nitrogen, E941
- carbon dioxide, E290
- "Packed in a modified atmosphere".
Preservatives and antioxidants:
- Lysozyme, E1105
- Potassium sorbate, E202
- Dimethyldicarbonate (DMDC), E242
- L-ascorbic acid, E300
- Sulphites
Food additives shall be listed with the class name followed by the name or E-number:
The class name clarifies which tasks the substance performs in a food (e.g. stabilisers).
Oenological processing additives
Substances that are not listed in the list of ingredients
(complete list in EU Regulation 2019/934).
- all deacidification substances
- Adsorbents - (activated carbon, selective plant fibres).
- Fermentation agents - (yeasts, bacteria)
- Enzymes
- activators for alcoholic and malolactic fermentation
Fermentation - (nutrients, inactivated yeasts)
- Clarifying agents - (gelatine, PVPP, bentonite, tannins,...)
- Stabilisers - (contact tartar)
- Correction of deficiencies - (copper sulphate, copper citrate)
Additives of the categories "acidity regulators" and "stabilisers" may be combined with "and/or".
Example: "Acidity regulators: Tartaric acid (L+) and/or malic acid and/or lactic acid".
Even if the wine contains only one of these substances, a list of all possible alternative substances in the category may follow. This is to ensure that ad hoc decisions can still be made during bottling. A colon shall be added after the term of the category
("acidity regulators:" "stabilisers:" etc.).
Gases
Gases do not have a class name placed in front. The gases carbon dioxide, argon and nitrogen used in bottling displace oxygen in bottling but do not become part of the product.
Decisions on the use of gases are sometimes made at short notice and the inclusion of gases in the list of ingredients can confuse consumers about the composition of the wine.
Gases are listed in the list of ingredients as follows: "bottled in a modified atmosphere" or "bottling may have taken place in a modified atmosphere."
The chemical name or E-number shows which substance is involved (e.g. citric acid or E 330). The E-numbers are a kind of code by which these additives can be identified regardless of language. Since additives often have complicated chemical names, the ingredient list of products can be made clearer and shorter if only the corresponding E-number is marked instead of the full name.
Allergens
Substances that can trigger allergies or intolerances must be listed in the list of ingredients. Furthermore, these substances and products must be additionally highlighted in the list of ingredients, e.g. by the font, the font style (e.g. bold print) or the background colour.
The term "sulphites" is used in the list of ingredients. In the case of a QR code, the term "Contains sulphites" shall be used on the label as before.
Processing aid
Processing aids are used temporarily in the production of a food and are subsequently removed. However, unintentional and technically unavoidable traces may be present in the final product, provided that the residues do not pose a health risk and do not have a technological impact on the final product. Processing aids are not listed in the list of ingredients.
An exception are allergens, which must always be indicated, such as milk and egg in a concentration of more than 0.25 mg/l.
Sulphur dioxide and sulphites must be indicated in a concentration of more than 10 mg/l.
Processing aids are, for example, deacidification substances, activated charcoal, activators for alcoholic and malolactic fermentation, inactivated yeasts, bacteria, clarification aids, contact tartar, enzymes, copper sulphate and others.
In simpler terms, processing aids are all substances that are permitted and are not an ingredient. The complete
list can be found in EU Regulation 2019/934.
Language
Current knowledge is that there are conflicting statements on language, while EU Regulation 2013/1308 Article 121 states that "(1) Where the mandatory and optional particulars ... are given, this must be done in one or more official languages of the Union."
Does the Food Information Regulation (FID) Article 15 say "... mandatory food information shall be drawn up in a language easily understood by consumers of the Member States in which a food is marketed."
There are so-called General Conflict of Laws according to which:
The more specific law displaces the general one. The later law supersedes the earlier one. The higher-ranking law supersedes the lower-ranking law. It is not yet clear which rule will apply here.
For exports to EU countries, it certainly makes sense to prepare ingredients and nutrition labelling in a language easily understood by consumers in the member states where a food is marketed.
The labelling of allergens must be in a language easily understood by consumers of the Member State in which the wine is marketed, as is already the case.
Examples of labels
A minimum font size of at least 1.2 mm x-height applies to labels. The x-height is the regular height, measured from the base line, of the lower case letters of a font that has no ascender, such as the x. Different specifications apply to the font size of the nominal volume, which depends on the bottle size and is 4 mm for a nominal volume of 200 to 1000 ml. The following label examples are not to scale.
Conclusion:
With the EU Regulation 2021/2117, the declaration of wine will be adapted to the existing regulations for food.
The list of ingredients and the nutrition declaration will be added to the list of mandatory information. For a calculation of carbohydrates and calorific value, an analysis of alcohol, glycerine (here, an empirical value, e.g. 10% of the existing alcohol content, could also be used), sugar and total acidity is required.
The list of ingredients distinguishes between "food additive" and "processing aid", only additives are listed. Everyone who markets wine to end consumers will have to adapt wine labels, price lists and web shops and can already prepare themselves today.
Source : Bernhard Schandelmaier
