Revision of wine labelling

Commission Delegated Regulation (EU) 2023/1606 of 30 May 2023 amending Delegated Regulation (EU) 2019/33 as regards certain provisions on protected denominations of origin and protected geographical indications for wine and on the presentation of compulsory particulars for grapevine products and specific rules for the indication and designation of ingredients for grapevine products, and Delegated Regulation (EU) 2018/273 as regards the certification of imported wine products

Update

This Regulation aims to improve consumers’ understanding of wine labels. It clarifies certain terms that may be used on the list of ingredients on wine labels.

What is changing?

The European Commission has updated existing rules relating to wine labelling (Delegated Regulation (EU) 2019/33, Chapter IV). The most significant changes are:

List of ingredients

In the list of ingredients, the following terms may be included.

• "Grapes", regardless of whether grapes or grape must are used as raw materials.
• "Concentrated grape must", regardless of whether the grape must used is “concentrated” and/or "rectified concentrated".
• Additives permitted in the production of wine and processing aids ("oenological compounds") that may cause allergies or intolerances (those included in Annex I, Part A, Table 2, column 1 of Delegated Regulation2019/934).
• The expression "contains" "acidity regulators" and "stabilising agents", followed by an exhaustive list of additives falling under these categories where at least one of those additives is present in the finished product. This avoids constantly changing wine labelling for these types of additive which are used as needed.
• "Bottled in a protective atmosphere" or "bottling may have been in a protective atmosphere", rather than the category "packaging gases". This avoids consumer confusion as packaging gases do not form part of the final product.
• The terms "tirage liqueur" and "expedition liqueur", with the possibility to list their constituents in brackets. This avoids consumers thinking that these constituents are used for sweetening or enriching rather than as part of the production process.

Additional points

• Today, for bottles of sparkling wine (including quality and quality aromatic sparkling wines) larger than 0.2 litres, the bottle openings must be sheathed in foil. The Commission now allows producers of these products the option not to sheath bottle openings in foil.
• The rules now clarify that the term "medium sweet" refers to a sugar content that does not exceed 45 g/l and exceeds 12 g/l or 18 g/l, provided the total acidity (grams per litre) is not more than 10 g below the residual sugar content (i.e. the definition of “medium dry”). The second criterion was not explicit in the existing rules.

Why?

The Regulation aims to clarify the terms that are used on wine labels. It ensures that consumers are not confused by the ingredient lists, in particular regarding additives used in the winemaking process that are not present in the final product. The Regulation also takes into account practicalities of winemaking and potential burdens on winemakers, particularly micro-enterprises, of rules that would require frequent changes to labelling.

Timeline

Applies since 28 August 2023.

The revised rules on the list of ingredients apply from 8 December 2023.

What are the major implications for exporting countries?

The new rules relating to the list of ingredients are not mandatory, but reflect what the EU considers "should apply" (recital 8).

Recommended Actions

Suppliers of wine should evaluate how existing labels can be aligned with the new rules to meet the objectives of improving consumers' understanding of wine labelling.

Background

Regulation (EU) 1308/2013 (Art. 119) sets out the information that must be included on labels or in the presentation of "grapevine products" (wine, liqueur, sparkling wine), including provenance, alcohol strength, and terms related to geographical indication. Commission Delegated Regulation (EU) 2019/33 elaborates more detailed rules relating to geographical indications and the labelling and presentation of wine.

Resources

Sources