Wine and spirits labelling: ingredients, nutrition and allergens

Since 8 December 2023, wines and wine products must state the list of ingredients and the nutrition declaration — a revolution for the sector. This guide covers all labelling obligations for wines, aromatised wines and spirits on the European market, including digital labelling (e-label) and the pregnancy warning pictogram.

1. Regulatory framework

Wine labelling is based on several interlinked texts:

• Reg. (EU) 1308/2013 (CMO wine) — Basic rules: denominations, categories, PDO/PGI
• Reg. (EU) 2019/787 — Definition and protection of spirit drinks (Cognac, Whisky, Rum, etc.)
• Reg. (EU) 2021/2117 — CMO amendment requiring ingredients and nutrition for wines from 08/12/2023
• Reg. (EU) 1169/2011 (FIC) — General food labelling rules applicable by reference
• Delegated Reg. (EU) 2019/33 — Presentation and labelling of wine products

2. Mandatory mentions — wine

Every wine label marketed in the EU must display:

• Category denomination — PDO, PGI, or regulated category
• Alcoholic strength by volume (ABV) — In "% vol." with at most one decimal
• Volume — Nominal volume in litres, centilitres or millilitres
• Allergens — Sulphites (if > 10 mg/L), milk, eggs (used as fining agents)
• Lot number — Preceded by "L" or unambiguously identifiable
• Bottler — Name and municipality
• Country of origin
• Residual sugar (sparkling wines) — Brut nature, Extra brut, Brut, Extra dry, Dry, Medium dry, Sweet
• Ingredients (since 08/12/2023) — Full list or via e-label
• Nutrition declaration (since 08/12/2023) — Energy value mandatory on physical label

3. 2023 novelty: ingredients and nutrition

Regulation (EU) 2021/2117 amended the CMO to align wine with FIC obligations. Since 8 December 2023, any wine from grapes harvested after that date must indicate:

• The complete ingredients list (grapes, sugar, sulphur dioxide, tartaric acid, fining agents, etc.)
• The nutrition declaration — at minimum the energy value on the label, full details may be referred to digital support

Wines produced before that date and already in stock may continue to be sold with old labels until depleted.

4. E-label — digital labelling

The digital support (e-label) is a web page accessible via a QR code on the label. It allows deferral of the ingredients list and detailed nutrition declaration. Conditions:

• The QR code must be in the same visual field as ABV and volume
• The word "ingredients" or associated pictogram must accompany the QR code
• The landing page must contain no commercial content or marketing trackers
• Information must be available in the language of the country of sale
• The page must remain accessible as long as the product is on the market

5. Spirits — Regulation (EU) 2019/787

Spirits have their own denomination and geographical protection rules. Mandatory mentions include:

• Legal denomination (Cognac, Whisky, Rum, Gin, Vodka, etc.)
• ABV in "% vol."
• Nominal volume
• Allergens (sulphites if applicable)
• Name and address of the person responsible for marketing
• Country of origin
• Lot number

For spirits, ingredients and nutrition declaration also became mandatory (with e-label option) from 08/12/2023 for new products.

6. Pregnancy warning pictogram

In France, the pregnancy pictogram is mandatory for all beverages above 1.2% vol. alcohol (Decree 2007-877). It may be replaced by a text message about risks of alcohol during pregnancy.

At EU level, the pictogram is recommended but not yet mandatory. However, several Member States have made it mandatory by national decree (France, Ireland). The European trend is towards mandatory harmonisation.

7. Common mistakes

• Sulphites not declared as allergen
• ABV incorrectly rounded (e.g. 13.47% displayed as 13% instead of 13.5%)
• E-label linking to a marketing page instead of a pure informational page
• Energy value absent from physical label (referred only via QR code)
• "Estate bottled" used for wine not bottled at the estate
• Missing pregnancy pictogram for French market
• Ingredients list missing for a 2024 vintage

Frequently asked questions

Are ingredients mandatory on wine labels since 2023?

Yes. Since 8 December 2023, any wine from grapes harvested after that date must list ingredients, either directly on the label or via an e-label (QR code to an informational page). The energy value must in all cases appear on the physical label.

Can the e-label QR code replace the ingredients list on the bottle?

Yes, but under strict conditions. The ingredients list and detailed nutrition may be deferred to a web page via QR code. However, the energy value (kJ/kcal) must remain on the physical label. The e-label page must contain no commercial content.

Is the pregnancy pictogram mandatory across the EU?

Not yet at EU level. However, France made it mandatory via Decree 2007-877 for all alcoholic beverages above 1.2% vol. Ireland has also adopted similar rules. The European trend is towards mandatory harmonisation.