Wine Label Requirements Under Regulation (EU) 2021/2117 Explained

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Since 8 December 2023, wine sold in the European Union has to show more than it used to. Regulation (EU) 2021/2117, adopted on 2 December 2021, amended the Common Market Organisation Regulation, Regulation (EU) No 1308/2013, to make an ingredient list and a nutrition declaration compulsory for wine and aromatised wine products.

This guide sets out what actually changed, what must appear on the physical bottle, and what you are allowed to move to a digital wine e-label behind a QR code.

What changed on 8 December 2023

Before the change, wine was largely exempt from the ingredient and nutrition rules that apply to most food and drink. Regulation (EU) 2021/2117 removed that exemption. From the date of application, wine and aromatised wine products placed on the EU market must carry a full list of ingredients and a nutrition declaration.

The European Commission states the rules apply to all wines obtained from the 2024 harvest onward. Wine that was legally produced, labelled or imported before 8 December 2023 may continue to be marketed until stocks are exhausted.

What must stay on the physical label

Two things can never move off the bottle:

• The energy value; and
• All substances or products that cause allergies or intolerances (for example sulphites, or egg and milk derived fining agents).

These must always appear on the physical package or a label attached to it. This is confirmed in European Commission Notice C/2023/1190 (Q9).

What can move to a QR e-label

The full ingredient list and the full nutrition declaration may be provided electronically, through a QR code or link on the label. That electronic page is the e-label. The legal basis is Article 119(4) of the amended Regulation 1308/2013.

The e-label is not a free-for-all, though. Under the conditions that accompany electronic labelling, the mandatory information must not be shown together with information intended for sales or marketing, and no user data may be collected or tracked. We cover those limits in detail in our guide on why a wine e-label cannot track users or show marketing.

Which products are covered

The scope covers wine, sparkling wine, fruit wine and aromatised wine products. If you place any of these on the EU market, whether you are an EU winery, an importer, or a non-EU producer exporting into the EU, the requirement applies to you.

Frequently Asked Questions

When did the wine ingredient and nutrition rules start?

They entered into application on 8 December 2023, under Regulation (EU) 2021/2117 amending Regulation (EU) No 1308/2013. Stock produced, labelled or imported before that date can be sold until it runs out.

Do I have to print everything on the bottle?

No. The energy value and allergens must be on the physical label, but the full ingredient list and full nutrition declaration can be provided through a QR code that opens an e-label page.

Does this apply to imported wine?

Yes. Any wine placed on the EU market must comply, regardless of where it was produced.

A note on sources: the interpretive detail in this article follows European Commission Notice C/2023/1190. The exact wording of Article 119(4) and (5) should be confirmed against the current consolidated text on EUR-Lex before being quoted verbatim. This article is general guidance, not legal advice.

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