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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 under Article 6, Paragraph 5 of Regulation (EU) 2021/2117: starting on 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 have extracted the most important information from the Regulation of the European Parliament and the Council for you.
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 the 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 may cause allergies or intolerances.
What and how to label
As of December 8ᵗʰ, 2023, EU wine label requirements are in effect. These requirements apply to products produced after this date.
Attention:
Production refers to the fermentation process (primary or secondary) that results in a vine product. Filling the product into containers and labeling it do not count as production for this purpose. Thus, this obligation applies, for example, to late-harvest wines such as 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 labels for both domestic and imported products packaged for consumers.
- The information must be presented in a language easily understandable to consumers in the EU member states where the product is marketed. In the Czech Republic, surprise! – Czech is required.
- If you sell 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 both on the product webpage and on the bottle.
- If wine is transferred from bulk containers into consumer packaging, this information must be provided, for example, via accompanying documents.
You do not have to label:
- • Products produced before December 8ᵗʰ, 2023.
- • Wine 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 to provide it electronically, i.e., via any machine-readable code that offers direct access to mandatory information. A device with universal access (e.g., a smartphone) must be able to scan or read the code and instantly convert it into a URL.
- The code must be accompanied by a notice indicating that it contains specific data (nutritional values, ingredient 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 have created the QR Wine application, which elegantly addresses the EU wine label requirements. 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 maintain reliable records—all in one place.
- Legislative obligation fulfilled
- All essential information in one place
- An elegant solution for mandatory labeling
Do you like the QR Wine app? Would you like to collaborate with us on other digital projects? In addition to developing mobile and web applications, we also specialize in digital marketing and 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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