EU wine labelling changes: digital solutions essential to avoid overcrowded back labels

One of the biggest challenges we face when creating new Spanish wine brands is ensuring that the labels compile with all the rules and regulations imposed by both the Spanish Designations of Origin, other certification bodies and the markets in which they will be sold. This process will be further complicated by extensive changes to labelling law imposed by the EU later this year.

Current labelling requirements

Getting a new brand to market is never easy and it can often be a lengthy process. We start with a brief of what we are hoping to achieve and a draft timeline, but there are invariably delays as we pass through various stages of design and approval.

Once artwork is ready, it must be approved by the regional body, usually the Regulatory Council of the Protected Designation of Origin. It checks for things like the minimum size of the lettering used for the region’s name, and the use of regulated phrases such as “Crianza”, which can only be used for wines that meet minimum ageing requirements. In certain regions, such as DO Ribera del Duero, there are further stipulations, for example, the designation “Old Vines” can only be used be used for wines made in their entirety from vines aged 35 years or more, and must be complemented by the specific age of the vines. Similarly, “Vines at Altitude” can only be used if a height above sea level is mentioned.

Once that stage has been passed, further checks need to be made in conjunction with any importers to ensure that the label meets legislative requirements for sale in a given market. For example, wines sold in the USA need a government health warning statement to be featured on the back label, meaning that we usually need to print separate back labels for wines shipped to the USA.

Although the labelling laws are largely standardized across the EU, there are some differences by country. For instance, in France, there has been a legal requirement since 2007 to include a pregnancy warning text or pictogram.

For organic and vegan wines, such as Melea, there are additional logos to be included as a matter of course.

It has long been necessary to also include allergen labelling across the EU. In the case of wine, this usually means including the phrase “contains sulphites” in the official language of the country it will be sold in. As there are 24 official languages across the EU, that’s a further 20+ texts to be included at the minimum sizing, alongside other essential requirements such as ABV, size of bottle, bar code, recycling symbol, name of producer and phrases such as “Product of Spain”… Squeezing it all on is quite a challenge and it’s about to get even harder…

 

New EU labelling requirements from 2023

All wines produced after the 8^th December 2023 and sold in the EU will also be required to include allergy, energy (i.e. calories), ingredient and nutritional information to consumers on their labels.

The (moderately) good news is that while intolerance, allergy (the existing sulphites message) and energy information (usually given in kcal/kJ per 100ml) MUST be printed directly on the label, required ingredient and nutrition lists can be provided electronically via QR code or a link, leading to an independently hosted e-label. Like the allergen information (sulphites) this must also be translated into all the official languages of the EU countries where the product is sold. If the product is to be sold in Italy, information on recycling must also be provided here.

However, this cannot link directly to an existing brand website, as the EU requires no user data to be collected or tracked and the list of ingredients cannot be displayed with other information intended for sales or marketing purposes.

This means that the “e-label” business is booming, as third parties offer codes that link to “clean pages” with no cookies or tracking information (even Google analytics could invalidate the terms) to provide the requisite ingredient information.

You can already see QR codes on the back labels of several of our brands; expect to see them on many more over the next few months…

Of course, although compliance is complicated, we could look on the bright side, for consumers this is a big plus in terms of transparency, and will show how many Spanish wines are made in a “pure” way with no unnecessary additives.

In the meantime, spare a thought for the brand owners and wineries who have a big task ahead in ensuring compliance over the next six months, not to mention additional costs to add to already squeezed margins!