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For wine producers within the European Union (EU), or those wishing to sell wine in the EU, adhering to wine labeling laws is of utmost importance. These laws ensure transparency, protect consumers, and maintain the integrity of the wine industry. If you are a wine producer in the EU, it is crucial to understand the requirements for analysis and labeling that you must fulfill. Regulation E.U. 2021/2117 requires nutrition, energy, and allergen information to be disclosed on wine sold in the E.U. starting December 8, 2023. Let's explore these requirements in detail.
To meet EU wine labeling laws, wine producers must conduct certain analyses to assess the quality, authenticity, and safety of their wines. These analyses are typically carried out in accredited laboratories and cover various aspects. Here are some key analysis requirements:
- Chemical Analysis: Wine must undergo chemical analyses to determine parameters such as alcohol content, total acidity, volatile acidity, residual sugar, and pH level. These parameters provide essential information about the composition and balance of the wine.
- Sensory Analysis: If your wine comes from within the EU, sensory evaluation involves the assessment of wine's organoleptic properties, such as aroma, taste, color, and overall quality. Trained sensory panels or experts conduct these analyses to ensure the wine meets quality standards.
- Microbiological Analysis: Microbiological analyses are crucial for assessing the microbiological stability and safety of the wine. These tests identify the presence of harmful microorganisms, such as yeasts, molds, and bacteria, that can affect the wine's quality and pose health risks.
Once the necessary analyses have been conducted, wine producers must ensure their labels comply with EU regulations. Here are the key labeling requirements to fulfil:
- Geographical Indication (GI): EU wine labeling laws place great importance on geographic indications, indicating the wine's origin and protecting regional traditions. Producers must accurately indicate the wine's specific geographic origin, such as Protected Designation of Origin (PDO) or Protected Geographical Indication (PGI).
- Wine Category and Style: The label should clearly indicate the wine's category and style. For example, terms such as "table wine," "quality wine," or "sparkling wine" should be appropriately used to convey the type and quality level of the wine.
- Alcohol Content: The alcohol content must be clearly displayed on the label. It is typically stated as a percentage of volume and can help consumers make informed decisions regarding the strength of the wine.
- Allergen Information: If any allergens, such as sulfites, are present in the wine above a certain threshold, their presence must be declared on the label. This is to ensure consumers with allergies are aware and can make informed choices.
- Language Requirements: EU wine labels must include specific information in the language(s) of the member state(s) where the wine is marketed. This typically includes the name of the wine, category, alcohol content, and allergen information.
Additional requirements exist. Specific wine labeling requirements may vary among EU member states, so it is essential to familiarize yourself with country-specific regulations. This may include additional labeling elements such as vineyard name, vintage, grape variety, aging information, and sustainability certifications.
By adhering to these analysis and labeling requirements, wine producers in the EU can ensure compliance with the law and provide consumers with accurate information about their wines. It not only protects consumers but also helps to build trust and maintain the reputation of the EU wine industry.
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Winemakers in Europe are preparing to comply with Regulation (EU) 2021/2117 and other related regulations concerning wine labeling. This includes disclosing nutrition, energy, and allergen information on wine sold within the EU starting from December 8, 2023. An update to the laws, Regulation (EU) 2023/3257, was published on May 30, 2023, introducing notable changes. These changes include clarifications on displaying allergens and intolerances, regulations related to additives that vary between bottles, and new rules for wines with alcohol content less than 10% ABV and less than 0.5% ABV.
The updated regulation provides clarification on disclosing additives, considering the variations that may occur from one bottle to another. To accommodate the practical challenges faced by winemakers, the regulation requires an exhaustive list of potential additives that could be used in the winemaking process to be included on the product's ingredient list. It is recognized that not all additives listed may be present in each bottle of wine. For additives in the sub-categories of acidity regulators and stabilizing agents, specific requirements are set, and the ingredient list must include no more than three additives, with at least one expected to be present in the final product. The regulation also addresses packaging gases, which can be omitted from the ingredient list if the producer includes statements such as "Bottled in a protective atmosphere" or "Bottling may happen in a protective atmosphere."
Regarding allergens and intolerances, the regulation clarifies that they must be printed on the product label, even if electronic labels are used. The concept of the "field of vision" is crucial in determining where these compulsory particulars should be placed. Anything that is legible without the need to turn the package or bottle is considered within the field of vision. While certain items, such as substances causing allergies or intolerances, importer information, lot number, and date of minimum durability, are allowed to be listed outside the field of vision, they are still required on the label or attached to the wine bottle.
These updates to EU wine labeling laws aim to ensure transparency, provide important information to consumers, and maintain the integrity of the wine industry. Winemakers should familiarize themselves with these requirements to ensure compliance and continue to deliver high-quality wines to the market.
Overall, EU wine labeling laws impose strict requirements on wine producers. Analysis of key parameters and adherence to accurate labeling are essential for compliance and commercial success. By conducting chemical, sensory, and microbiological analyses, producers can assess the quality and safety of their wines. Additionally, fulfilling labeling requirements regarding geographic indication, wine category, alcohol content, allergen information, language, and any country-specific regulations ensures transparency and aids consumers in making informed choices. By following these requirements, wine producers will successfully navigate the complex landscape of EU wine labeling laws and contribute to the wine industry’s overall integrity and reputation.
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