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New obligations for producers and distributors of vine products
Wine producers, grape processors, and distributors of vine products will have a new obligation according to Article 6, paragraph 5 of Regulation (EU) 2021/2117: starting from December 8ᵗʰ, 2023, they must include nutritional information and an ingredient list on their product packaging. What data is required? How should it be labeled? What does this mean for producers in practice? We tried to extract the most important information for you from the regulation (we used this source: State Agricultural and Food Inspection Authority, which will oversee the compliance with the new regulation).
Mandatory Information
• Mandatory nutritional information
Energy value: must be indicated in kJ (kilojoules) and kcal (kilocalories) in that order (the abbreviation kJ/kcal may be used). The value refers to 100 ml of beverage.
Amount of fats, saturated fatty acids (referred to as 'SFA'), carbohydrates, sugars, and proteins.
• Composition
All additives used in the production of vine products that remain present in the finished product (even in altered form).
All processing aids used in production that cause allergies or intolerances.
What and how to label
Labeling applies to products made after December 8ᵗʰ, 2023.
Attention:
Production is understood as the fermentation process (primary or secondary), resulting in a vine product. Filling the product into containers and labeling it does not count as production for this purpose. Thus, the obligation will apply to, for example, late harvest wines like straw wine, ice wine from the 2023 vintage, or sparkling wines whose secondary fermentation occurred after this date.- Nutritional information and the ingredient list must be provided on the labels of products (domestic and foreign) packed in consumer-ready packaging.
- The information must be presented in a language easily understandable to consumers in EU member states where the product is marketed. In the Czech Republic, surprise! – Czech is required.
- If you offer products through an e-shop, the mandatory information (including the ingredients list and nutritional values) must be available before completing the purchase and at the time of delivery. We interpret this to mean that the information must be displayed on both the product webpage and the bottle.
- If wine is to be filled into consumer packaging from bulk containers, this information must be provided, for example, via accompanying documents.
You do not have to label:
- • Products produced before December 8ᵗʰ, 2023.
- • If the wine is intended for sale in barrels, on tap, or by the glass.
Electronic means
- You may present the required information in text on the packaging or label, but a more practical option is providing it electronically, i.e., via any machine-readable code that offers direct access to mandatory information. A device with universal access (smartphone) must be able to scan/read the code and instantly convert it into a URL.
- The code must be accompanied by a notice that it contains specific data (nutritional values, ingredients list).
- Data provided by electronic means MUST NOT display any information intended for promotional or marketing purposes. At the same time, no user data may be collected or tracked.
Attention:
This means that the obligation cannot be fulfilled on the manufacturer's website, as it contains information relevant to marketing or seller data. Moreover, websites typically track user information.
A solution called QR Wine
At our digital agency Adbros, we created the QR Wine application, which elegantly solves this new obligation. The app assigns all necessary values to each variety or batch and then generates a QR code, creating a simple webpage with all mandatory information. This way, customers can easily access the information, you meet the obligation effortlessly, and you also get reliable records all in one place.
- Legislative obligation fulfilled
- Overview of everything in one place
- Elegant solution to mandatory text
Do you like the QR Wine app? Would like to collaborate with us on other digital projects? In addition to developing mobile and web applications, we also focus on digital marketing or graphic design. Need a custom digital solution? Drop us your contact info, and we will get back to you.
We’re glad you’re interested
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