Since December 2023, the labeling of wines has undergone significant changes following the introduction of Regulation (EU) 2021/2117. These changes have made it mandatory to include ingredients and a nutrition declaration in the labeling of wine products, necessitating a reassessment of labeling practices in the wine sector.
Concerning the indication of ingredients, as stipulated in point 38 of the Commission Guidelines, article 18, paragraph 1, of Regulation (EU) 1169/2011 explicitly requires that the list of ingredients is preceded by an appropriate heading that includes or consists of the word “ingredients.”
Paragraph 8 of Article 5 of Regulation (EU) No 2021/2117 sets 8 December 2023 as the date of entry into force of the new labeling rules under Article 119 of Regulation (EU) 1308/2013. These rules allow, in derogation from the general principle, the provision of the list of ingredients and the nutrition declaration electronically, through the use of a QR code.
However, the complexity of the rules and the need for clarification regarding the identification and accessibility of information associated with the QR code require a more detailed analysis.
The final clarifications are found in the response of Commissioner for Agriculture Wojciechowski dated 12 March 2024, highlighting that the mere presence of an unidentified QR code on a label does not meet the required standards. Additionally, the interpretation of the provisions of Regulation (EU) 1169/2011 underscores the importance of ensuring that mandatory food information is easily identifiable and clearly legible. This issue has been the subject of discussion in various meetings with Member States, highlighting the need for a coordinated approach within the European Union.
Regarding the possibility of abbreviating the term “ingredients” or using the ISO 2760 “i” symbol when the list of ingredients is provided electronically, a thorough examination of all the mandates conferred by Regulation (EU) 1308/2013 was conducted. However, it was found that none of these mandates authorize the Commission to make such a modification based on existing mandates. It is important to note that the language rules applicable to this term are the same as those currently applied to other mandatory indications on labels, as specified in point 38 of the Commission Guidelines.
The situation following the issuance of the Guidelines has posed challenges for producers, who have had to adapt to the new regulations, printing numerous labels that subsequently did not conform to the Commission’s interpretation. In Italy, Ministerial Decree 115268 of 8 March 2024 extended until 30 June 2024 the deadline for using the derogation for the marketing of wines and flavored wine products bearing the “i” symbol next to the QR code, in order to ensure compliance with economic and environmental sustainability principles. However, this option is limited to products circulating within the national territory.
In case of remaining unused labels within the indicated deadline, it is permitted to correct them by affixing a sticker containing the wording “ingredients” next to the symbol “i” or other indications deemed useful. It is also emphasized that products labeled following the provisions of the Ministerial Decree may be marketed within the national territory until stocks are exhausted.
About the nutrition declaration, paragraph 4 of article 119 of Regulation (EU) 1308/2013, as amended by Regulation (EU) 2021/2117, stipulates that it may be limited to the energy value on the physical label, while the full nutrition declaration must be provided electronically.
This underscores the importance of ensuring that consumers can access comprehensive and accurate information, regardless of the means used.
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