Who, what and from when
Regulation (EU) 2021/2117 of 2 December 2021 amended, among others, Regulation (EU) No 1308/2013 (the CMO Regulation). It requires wines and aromatised wine products to give an ingredients list and a nutrition declaration, and it applies from 8 December 2023.
Wines "produced" before that date can keep being placed on the market under the previous rules until stocks are exhausted. The information is the responsibility of the operator placing the wine on the market.
What the articles relevant to an e-label say
The ingredients list and the nutrition declaration are mandatory particulars under Article 119. They may be given on the physical label or by electronic means. If the full declaration is given by electronic means, the energy value has to appear on the physical label, and allergens stay on it.
Article 119(5) provides that this information may not be displayed alongside sales or marketing information and that no user data may be collected or tracked. Access must be direct, without going through forms.
- The link or QR code in the same field of vision as the other mandatory particulars.
- A word that identifies what is behind it, such as "ingredients".
- Energy in kJ and kcal per 100 ml on the bottle, with "E" as an optional symbol.
- No shop, no marketing and no user tracking.
Where to find the official text
This page summarises the regulation and does not replace the official text. The regulation is published in the Official Journal (OJ L 435, 6.12.2021, p. 262) and the Commission published a questions and answers notice (OJ C, C/2023/1190, 24.11.2023) with guidance on how to apply it.
Frequently asked questions
From when is the electronic wine label mandatory?
The obligation to provide ingredients and nutrition information applies from 8 December 2023. The e-label is the option for providing that information by electronic means.
Is it mandatory to use a QR code?
No. You can print the ingredients list and the full declaration on the label. The regulation does not set a specific electronic means; the QR code is the usual choice.
Which wines are exempt while stocks last?
Those produced before 8 December 2023, which can be sold under the previous rules until stocks run out. When a wine counts as "produced" is defined in the regulation.
Who checks compliance?
The national authorities of each Member State. That is why it is worth checking each wine against the rules of the country where it is sold.
