According to Regulation (EU) 2021/2117, starting December 8, 2023, wines produced in the European Union must include a list of ingredients and a nutritional declaration on their labels. This requirement applies to wines produced from the 2024 harvest onward, excluding older vintages. The regulation allows for the information to be provided physically (printed on the label) or digitally via QR code; the latter method is the one chosen by all operators, both for the label’s aesthetic cleanliness and to avoid immediately highlighting the presence of additives that most wine consumers are unaware of.
Below are the ingredient lists of four Italian wines (two DOC, one DOCG, and one IGP), chosen at random, as accessible only by scanning the QR code:
- Grapes, sucrose, preservatives: sulfites; stabilizing agents: gum arabic, potassium polyaspartate
- Grapes, concentrated grape must, acidity regulator: tartaric acid; Stabilizers: citric acid, carboxymethylcellulose; preservatives: sulfites
- Grapes, rectified concentrated must, preservatives and antioxidants: L-ascorbic acid, sulfites; acidity regulators: tartaric acid and/or lactic acid; stabilizers: yeast mannoproteins
- Grapes, concentrated grape must, alcohol, acidity regulator: tartaric acid; preservatives and antioxidants: citric acid, potassium sorbate, sulfites, dimethyl carbonate.
The rate of actual QR code scanning by consumers is not well documented, but although approximately a quarter (27%) of respondents in 14 European countries between November 2022 and March 2023 said they would scan a QR code available on the label, a pilot study by the World Health Organization Regional Office for Europe conducted at a supermarket in Barcelona, Spain, found that the rate of use among alcohol shoppers was 2.6 per 1,000 (0.26%).
The results of this pilot study, when considered together with data from the QR code preference survey, suggest a high likelihood that survey responses overestimate the likelihood of people actually using this information delivery medium; in short, QR codes are not widely used in real life. These results are consistent with the review conclusion mentioned in section 3.3.1 (Label information vs. digital media), which shows that the actual use of QR codes to obtain information on food products is low.
It would therefore appear that, at least for now, the greater transparency regarding the ingredients of wine products introduced by EU Regulation 2021/2117 is entirely virtual.
But the issue we intend to focus on is another. The regulation provides no guidance on how to proceed when wine is itself an ingredient in a composite product. This is not at all uncommon: just think of baked goods such as taralli, the syrups used in fine pastries, some cured meat products, ice creams, special jams and similar products, ragùs, and condiments in which wine is predominantly used as a flavoring, albeit generally in small quantities.
Before Regulation (EU) 2021/2117, the indication of wine ingredients was not Request; Regulation (EU) 1169/2011 merely excluded allergens from the exemption, requiring, in the absence of a list of ingredients, the indication “contains,” followed by the name of the allergenic substance (generally sulfites, but it could also be caseinates or ovalbumin used as stabilizers or fining agents). Any type of wine used in a composite product prior to Regulation (EU) 1169/2011 was therefore classified in the ingredients list simply as “wine,” while after the regulation it was classified as “wine (contains sulfites),” without prejudice to the option of providing further details on the type of wine with the prior authorization of the protection consortium.
Given that Regulation (EU) 2021/2117 does not introduce any exemptions, the requirement to detail the ingredients remains in place even for wine used as an ingredient in a composite product. Based on the carryover principle, additives and processing aids that, while remaining in the finished product, do not have a technological effect on it, can certainly be omitted (certainly fining aids and most stabilizers, while the situation with acidity regulators, preservatives, and antioxidants must be assessed on a case-by-case basis: although they are used in wine at quantum satis, a technological effect on the finished product cannot in principle be ruled out). Based on a non-exhaustive but diligent review of a broad selection of products on the market, all operators using wine as an ingredient in a composite product instead adopt the method required under Regulation (EU) 1169/2011 (i.e., “…, wine, …”, highlighting the presence of sulfites where applicable): none provide the details of the wine constituents now required by Regulation (EU) 2021/2117, either verbatim or with a QR code. It can reasonably be ruled out that this applies only to wines from harvests prior to 2024 and therefore exempt from the requirement.
The reference to Regulation (EU) 1169/2011, Annex VII, which does not require a list of ingredients when the composition of the composite ingredient is defined within the framework of existing EU provisions, appears to be inconsistent. This applies when the composite ingredient accounts for less than 2% of the finished product. First, it does not address cases where wine represents more than 2% of the total ingredients; furthermore, the exemption does not extend to additives and processing aids capable of performing a technological function in the finished product. Finally, it is doubtful whether the composition of wine can be considered precisely defined within the framework of EU provisions.
Regulation (EU) 2019/934 authorizes 19 oenological practices and 72 oenological compounds; for sparkling wines, it authorizes dosage liqueur composed (purely or in a blend) of sucrose, grape must, partially fermented grape must, concentrated grape must, rectified concentrated grape must, wine, and possibly the addition of wine distillate. It is clear that the extensive list of authorized practices and compounds provided by Regulation (EU) 2019/934 is not aligned with the need to ensure that consumers are adequately informed about the foods they consume, a cornerstone of Regulation (EU) 1169/2011: the ingredient list details of four randomly selected wines presented at the outset confirm the extreme variability in the composition of products on the market. In any case, even suspending judgment on the applicability of the derogation under point 2 of Annex VII, Part E, the case of exceeding the 2% threshold remains. In this case, there is no provision that would allow the list of constituents of wine used as an ingredient in a composite product to be declared voluntarily.
Wine is not among the ingredients expressly listed in Article 19 (“Omission from the list of ingredients”) or Article 20 (“Omission of constituents of a foodstuff from the list of ingredients”) of Regulation (EU) 1169/2011. Nor is it included among the categories for which Annex VII, Part B, authorizes the omission of the constituent details (it is limited to mixtures of spices, aromatic plants, and their parts that do not exceed 2% of the finished product).
The usual, widespread, and consolidated practice appears to be contra legem: even omitting the list of additives and processing aids with no technological effect on the finished product, it seems necessary to indicate at least “wine (grapes, concentrated grape must, preservatives: SULPHITES)” and, in the case of liqueur products, “wine (grapes, concentrated grape must, alcohol, preservatives: SULPHITES”).
While it might seem objectively disproportionate to include only two or three lines of ingredients (multiplied by the different language versions) given the use of small quantities, it should also be noted that Regulations (EU) 1169/2011 and 2021/2117, which amend previous legislation, require, without exception, the breakdown of the constituents of wine products that are ingredients of composite products.
Since there is no specific sanctioning framework, reference is made to Article 74, paragraph 1, of Law 238/2016, which provides for an administrative fine ranging from €250 to €5,000 and the resulting complexities (administrative seizures, recall obligations, and the need to send printed labels for recycling).
While waiting for this topic to be addressed in the revision of Regulation (EU) 1169/2011, expected in 2027, clearly defined guidelines from the industry would not be inappropriate, or, better yet, a Commission communication that eliminates any uncertainty for operators and supervisory bodies.
Home » Wine as an ingredient: what should be stated on the label?
Wine as an ingredient: what should be stated on the label?
Regulation (EU) 2021/2117 does not provide guidance on how to proceed when wine is an ingredient in a composite product. While waiting for this issue to be addressed in the revision of Regulation (EU) 1169/2011, expected in 2027, industry-defined guidelines or a Commission communication to eliminate any uncertainty would be appropriate
According to Regulation (EU) 2021/2117, starting December 8, 2023, wines produced in the European Union must include a list of ingredients and a nutritional declaration on their labels. This requirement applies to wines produced from the 2024 harvest onward, excluding older vintages. The regulation allows for the information to be provided physically (printed on the label) or digitally via QR code; the latter method is the one chosen by all operators, both for the label’s aesthetic cleanliness and to avoid immediately highlighting the presence of additives that most wine consumers are unaware of.
Below are the ingredient lists of four Italian wines (two DOC, one DOCG, and one IGP), chosen at random, as accessible only by scanning the QR code:
The rate of actual QR code scanning by consumers is not well documented, but although approximately a quarter (27%) of respondents in 14 European countries between November 2022 and March 2023 said they would scan a QR code available on the label, a pilot study by the World Health Organization Regional Office for Europe conducted at a supermarket in Barcelona, Spain, found that the rate of use among alcohol shoppers was 2.6 per 1,000 (0.26%).
The results of this pilot study, when considered together with data from the QR code preference survey, suggest a high likelihood that survey responses overestimate the likelihood of people actually using this information delivery medium; in short, QR codes are not widely used in real life. These results are consistent with the review conclusion mentioned in section 3.3.1 (Label information vs. digital media), which shows that the actual use of QR codes to obtain information on food products is low.
It would therefore appear that, at least for now, the greater transparency regarding the ingredients of wine products introduced by EU Regulation 2021/2117 is entirely virtual.
But the issue we intend to focus on is another. The regulation provides no guidance on how to proceed when wine is itself an ingredient in a composite product. This is not at all uncommon: just think of baked goods such as taralli, the syrups used in fine pastries, some cured meat products, ice creams, special jams and similar products, ragùs, and condiments in which wine is predominantly used as a flavoring, albeit generally in small quantities.
Before Regulation (EU) 2021/2117, the indication of wine ingredients was not Request; Regulation (EU) 1169/2011 merely excluded allergens from the exemption, requiring, in the absence of a list of ingredients, the indication “contains,” followed by the name of the allergenic substance (generally sulfites, but it could also be caseinates or ovalbumin used as stabilizers or fining agents). Any type of wine used in a composite product prior to Regulation (EU) 1169/2011 was therefore classified in the ingredients list simply as “wine,” while after the regulation it was classified as “wine (contains sulfites),” without prejudice to the option of providing further details on the type of wine with the prior authorization of the protection consortium.
Given that Regulation (EU) 2021/2117 does not introduce any exemptions, the requirement to detail the ingredients remains in place even for wine used as an ingredient in a composite product. Based on the carryover principle, additives and processing aids that, while remaining in the finished product, do not have a technological effect on it, can certainly be omitted (certainly fining aids and most stabilizers, while the situation with acidity regulators, preservatives, and antioxidants must be assessed on a case-by-case basis: although they are used in wine at quantum satis, a technological effect on the finished product cannot in principle be ruled out). Based on a non-exhaustive but diligent review of a broad selection of products on the market, all operators using wine as an ingredient in a composite product instead adopt the method required under Regulation (EU) 1169/2011 (i.e., “…, wine, …”, highlighting the presence of sulfites where applicable): none provide the details of the wine constituents now required by Regulation (EU) 2021/2117, either verbatim or with a QR code. It can reasonably be ruled out that this applies only to wines from harvests prior to 2024 and therefore exempt from the requirement.
The reference to Regulation (EU) 1169/2011, Annex VII, which does not require a list of ingredients when the composition of the composite ingredient is defined within the framework of existing EU provisions, appears to be inconsistent. This applies when the composite ingredient accounts for less than 2% of the finished product. First, it does not address cases where wine represents more than 2% of the total ingredients; furthermore, the exemption does not extend to additives and processing aids capable of performing a technological function in the finished product. Finally, it is doubtful whether the composition of wine can be considered precisely defined within the framework of EU provisions.
Regulation (EU) 2019/934 authorizes 19 oenological practices and 72 oenological compounds; for sparkling wines, it authorizes dosage liqueur composed (purely or in a blend) of sucrose, grape must, partially fermented grape must, concentrated grape must, rectified concentrated grape must, wine, and possibly the addition of wine distillate. It is clear that the extensive list of authorized practices and compounds provided by Regulation (EU) 2019/934 is not aligned with the need to ensure that consumers are adequately informed about the foods they consume, a cornerstone of Regulation (EU) 1169/2011: the ingredient list details of four randomly selected wines presented at the outset confirm the extreme variability in the composition of products on the market. In any case, even suspending judgment on the applicability of the derogation under point 2 of Annex VII, Part E, the case of exceeding the 2% threshold remains. In this case, there is no provision that would allow the list of constituents of wine used as an ingredient in a composite product to be declared voluntarily.
Wine is not among the ingredients expressly listed in Article 19 (“Omission from the list of ingredients”) or Article 20 (“Omission of constituents of a foodstuff from the list of ingredients”) of Regulation (EU) 1169/2011. Nor is it included among the categories for which Annex VII, Part B, authorizes the omission of the constituent details (it is limited to mixtures of spices, aromatic plants, and their parts that do not exceed 2% of the finished product).
The usual, widespread, and consolidated practice appears to be contra legem: even omitting the list of additives and processing aids with no technological effect on the finished product, it seems necessary to indicate at least “wine (grapes, concentrated grape must, preservatives: SULPHITES)” and, in the case of liqueur products, “wine (grapes, concentrated grape must, alcohol, preservatives: SULPHITES”).
While it might seem objectively disproportionate to include only two or three lines of ingredients (multiplied by the different language versions) given the use of small quantities, it should also be noted that Regulations (EU) 1169/2011 and 2021/2117, which amend previous legislation, require, without exception, the breakdown of the constituents of wine products that are ingredients of composite products.
Since there is no specific sanctioning framework, reference is made to Article 74, paragraph 1, of Law 238/2016, which provides for an administrative fine ranging from €250 to €5,000 and the resulting complexities (administrative seizures, recall obligations, and the need to send printed labels for recycling).
While waiting for this topic to be addressed in the revision of Regulation (EU) 1169/2011, expected in 2027, clearly defined guidelines from the industry would not be inappropriate, or, better yet, a Commission communication that eliminates any uncertainty for operators and supervisory bodies.
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