The Complete Guide to EU Wine Labeling 2026

Introduction

EU wine labeling has changed fundamentally since December 8, 2023. With EU Regulation 2021/2117, winemakers and wineries must now provide comprehensive nutritional information, ingredient lists, and allergen declarations for their wines. This change affects all wines produced after this date – regardless of whether they’re destined for domestic markets or export.

In this comprehensive guide, you’ll learn everything you need to know about compliant wine labeling: from the legal foundations to practical implementation and common pitfalls you should avoid.

What is EU Regulation 2021/2117?

EU Regulation 2021/2117 was adopted on December 2, 2021, and fundamentally changes existing wine market regulations. The core of this new regulation is the mandatory declaration of nutritional values, ingredients, and allergens for all wine products.

Legal Background

Historically, wine, sparkling wine, and other alcoholic beverages were exempt from general food labeling requirements. The European Commission has repealed this exemption with Regulation 2021/2117 to strengthen consumer protection and ensure transparent information about ingredients.

The regulation is part of a larger EU initiative to enable consumers to make informed purchasing decisions. Since wine is classified as a food product, consumers should receive the same information as they do for other food items.

Important Date: The new labeling requirements apply to all wines produced from December 8, 2023 onwards. Wines from earlier vintages bottled before this date may still be sold with the previous labeling – until stocks are depleted.

Which Products Are Affected?

The regulation covers a broad spectrum of wine products:

• Still wines (red, white, rosé)
• Sparkling wines and semi-sparkling wines
• Fortified wines
• Aromatized wine products
• Wine-based beverages

Not affected are grape must and unfermented grape juice, unless they are marketed as wine products.

Mandatory Information on Wine Labels

The EU regulation clearly distinguishes between information that must appear directly on the physical label and information that can alternatively be made accessible via an electronic label (e-label).

Directly on the Physical Label

These declarations must appear on the bottle itself – a mere reference to the QR code is not sufficient:

• Energy value in kJ and kcal per 100ml – This information must be on the physical label. The energy value is calculated according to an EU formula that considers alcohol content and residual sugar.
• Allergens – The statement “Contains Sulfites” (or additional allergens such as egg or milk when applicable) must be directly visible on the label.

The energy value declaration may be introduced by the abbreviation “E=” and must appear in a minimum font size of 1.2mm x-height.

Optionally on Label or E-Label

The following information can be provided either directly on the label or made accessible via QR code:

• Complete nutritional table with information on fat, saturated fat, carbohydrates, sugar, protein, and salt per 100ml
• Complete list of ingredients in descending order by weight
• Detailed allergen information beyond the brief statement

Many winemakers opt for the e-label solution since space on the bottle label is limited and the complete nutritional table would take up considerable room.

The E-Label Solution: QR Codes for Wine

An e-label is a digital supplement to the physical wine label. Via a QR code, consumers can use their smartphone to access a webpage containing all required mandatory information.

Technical Requirements

The EU regulation sets strict requirements for the technical implementation of e-labels:

1. No marketing content allowed – The e-label may only contain the prescribed mandatory information. Product descriptions, purchase recommendations, shop links, awards, or social media links are not permitted.

2. No data collection – Any form of tracking is prohibited. This means: no cookies, no tracking pixels, no analytics tools like Google Analytics, no storage of IP addresses or device information.

3. Retention period – E-label information must remain available for at least as long as the wine is on the market, plus an appropriate period for consumption. In practice, this means: at least 10 years of availability.

4. Quick accessibility – The QR code must lead directly to the information page, without detours through homepages or login areas.

5. Mobile-friendly – The page must be perfectly readable on mobile devices.

Benefits of the E-Label Solution

The digital option offers significant advantages over purely physical labeling:

• Space saving – More room for label design
• Multilingual – Automatic language detection for international markets
• Updatable – Changes possible without reprinting
• Sustainability – Less paper and printing consumption

Language Requirements for Export

The EU regulation requires that mandatory information be available in the official language of the respective sales country. This is particularly important for export-oriented wineries.

Important: “English as an international language” is not an acceptable alternative. The national language of the sales market is mandatory.

For multilingual countries like Belgium or Switzerland, information must be available in the official languages of the region where the wine is sold.

Intelligent e-label systems can automatically detect the smartphone’s language setting and display the appropriate language version. This significantly simplifies compliance since a single QR code can be used for all export markets.

Legal Consequences of Non-Compliance

Non-compliance with the new labeling requirements can have significant legal and economic consequences:

Administrative Measures

• Sales stop – Authorities can order an immediate sales stop for non-compliant batches. The product may only be returned to market after correcting the labeling.

• Recall – In severe cases, a product recall may be ordered, causing significant logistical costs.

• Fines – The amount depends on national food law. In Germany, violations of labeling requirements can be penalized with fines of up to €50,000.

Civil Law Risks

• Warning letters from competitors or consumer protection associations
• Compensation claims for allergic reactions due to missing allergen warnings

Reputational Damage

Beyond direct financial consequences, a public labeling deficiency can permanently damage customer trust. In the age of social media, such information spreads quickly.

Differences: Germany, Austria, Switzerland

Although the EU regulation sets the framework, there are national specifics to consider:

Germany

Implementation is through the Wine Act (Weingesetz) and Wine Ordinance (Weinverordnung). Food surveillance of the federal states is responsible for controls. German winemakers must pay particular attention to the correct indication of protected designations of origin (PDO) and protected geographical indications (PGI).

Austria

The Austrian Wine Act implements the EU requirements. Special attention deserves the DAC system (Districtus Austriae Controllatus), which sets additional requirements for origin designation.

Switzerland

As a non-EU member, Switzerland is not directly bound by the EU regulation. However: anyone exporting to the EU must fully comply with EU requirements. For the Swiss domestic market, the provisions of the Food and Commodities Ordinance (LGV) and the Beverages Ordinance apply.

Swiss wineries serving both the domestic market and EU export markets are best advised to use uniform labeling according to EU standards.

How to Create Compliant QR Codes in 5 Minutes

Creating EU-compliant e-labels doesn’t have to be complicated. With the right tools, implementation takes just minutes:

Step 1: Have Wine Analysis Ready

You need your wine’s analysis values, particularly:

• Alcohol content (vol%)
• Residual sugar (g/l)
• Total acidity (g/l)

These values are typically available from the laboratory or can be taken from the wine analysis.

Step 2: Have Nutritional Values Calculated

Specialized tools automatically calculate the required nutritional information from the analysis values according to the EU formula. You don’t need to perform complex calculations yourself.

Step 3: Enter Ingredients

Enter all ingredients used in winemaking: grapes (variety), sulfites, any fining agents (egg whites, milk products), grape must concentrate, etc.

Step 4: Select Export Markets

Choose the countries you export to. A good e-label system automatically creates the required translations.

Step 5: Generate QR Code

With one click, you receive a print-ready QR code that you can integrate into your label design.

Checklist: Is Your Wine Label EU-Compliant?

Use this checklist for self-assessment:

• Energy value (kJ and kcal) present on physical label
• Allergen warning (“Contains Sulfites”) on physical label
• Complete nutritional table accessible (label or e-label)
• Complete ingredient list accessible (label or e-label)
• E-label contains NO marketing content
• E-label uses NO cookies or tracking
• E-label available in language of all target markets
• Font size at least 1.2mm x-height
• QR code leads directly to information (no detours)
• E-label provider guarantees retention period

Common Mistakes to Avoid

These are the mistakes we see most frequently:

Energy value only in e-label – The energy value MUST appear on the physical label. A QR code reference alone is not sufficient.

Allergens hidden – Allergen warnings must be readable directly on the bottle, not only in the e-label.

Marketing in e-label – Awards, tasting notes, or shop links in the e-label constitute a legal violation.

Tracking built in – Google Analytics, Facebook Pixel, or other analytics tools in the e-label are prohibited.

Languages forgotten – For export, the national language is mandatory, not “international English.”

Conclusion and Next Steps

The new EU wine labeling requires careful implementation but is manageable with the right tools. What’s crucial is to act early and not wait until the last moment.

The e-label solution via QR codes offers the best compromise between compliance and practical feasibility. It saves space on the label, enables multilingual information, and can be updated when needed.

Your next steps:

1. Review your existing labels against the checklist
2. Gather the required wine analysis data
3. Test an e-label system with a trial wine
4. Plan the transition for your next labeling runs

With thoughtful preparation, you’ll master the new requirements smoothly and protect your winery from unnecessary risks.

Have questions about EU wine labeling? Contact us – we’re happy to help.