EU wine nutrition & ingredient labelling: the dated regulatory reference

Since 8 December 2023, every wine and grapevine product placed on the EU market must carry two labelling particulars it was previously exempt from: a nutrition declaration and a list of ingredients. The change was made by Regulation (EU) 2021/2117 of 2 December 2021, which amended the wine-labelling rules in Regulation (EU) No 1308/2013. Producers may keep only the energy value on the physical label and move the full nutrition table and ingredient list to an electronic label ("e-label") reached from the pack, provided that route collects no user data and carries no marketing. Allergens — sulphites above the threshold, egg- and milk-derived fining agents — must stay on the physical label under the horizontal food-information rules. This page is the dated reference for what the law says and when it applied; for the practical "how to build a compliant label / e-label" walkthrough, see MakeWine's separate /learn/eu-labelling guide, which links up to this reference rather than repeating it.

This is a summary, not legal advice — consult the official text and your national authority.

What Regulation (EU) 2021/2117 actually changed

Regulation (EU) 2021/2117, dated 2 December 2021, is the reform of the Common Market Organisation (CMO) that reworked the compulsory particulars for wine. It amended Article 119 of Regulation (EU) No 1308/2013 to add, for wine, the two obligations that already applied to most other foods: a nutrition declaration and a list of ingredients (CELEX 32021R2117).

Before this, wine was largely carved out of the horizontal nutrition and ingredient-listing duties. The reform closed that gap. The consolidated text of Regulation (EU) No 1308/2013 carries a consolidation date of 8 December 2023 — the point from which these wine provisions apply (EUR-Lex consolidated 02013R1308).

Two practical carve-outs sit inside the same regulation:

• Energy value on-pack, the rest electronically. A producer may display only the energy value on the physical label and make the full nutrition declaration and the list of ingredients available by electronic means, provided that route does not collect or track user data and is not used for marketing (Reg (EU) 2021/2117).
• Existing stocks run on. Wine produced and labelled before the application date may continue to be marketed until stocks are exhausted — the regulation's recital 42 states that "the marketing of existing stocks of wine should be allowed to continue after the dates of application of the new labelling requirements until those stocks are exhausted."

The e-label (off-label) option — and why it is "DPP-ready", not a DPP

The electronic route is commonly called the "e-label" or off-label. A QR code (or equivalent link) on the pack takes the consumer to the full nutrition table and ingredient list. Two hard limits from Regulation (EU) 2021/2117: the electronic destination must not gather user data or track the consumer, and it must not carry marketing content.

A note on scope, because the terms are routinely confused: wine's e-label is not the EU Digital Product Passport (DPP). The DPP is created under the Ecodesign for Sustainable Products Regulation (ESPR) and is being rolled out to product groups such as batteries, textiles and electronics — wine is not currently in ESPR/DPP scope. A well-structured wine e-label is therefore best described as "DPP-ready" (clean, linkable, machine-readable) rather than a DPP. Treat any claim that wine "needs a DPP" as inaccurate under the law as it stands.

Allergens: always on the physical label (FIC Regulation)

Allergen declaration for wine is governed by the horizontal Regulation (EU) No 1169/2011 — the Food Information to Consumers (FIC) Regulation, dated 25 October 2011 (CELEX 32011R1169). Its Article 9(1)(c) makes any ingredient or processing aid listed in Annex II a mandatory particular, and Article 21 requires those substances to be emphasised in the ingredient list (by font, style or background) so they stand out.

For wine this most often means:

• Sulphites / sulphur dioxide — the familiar "contains sulphites" declaration, triggered where SO₂ is present above the Annex II threshold (10 mg/L or mg/kg, expressed as total SO₂).
• Egg- and milk-derived fining agents (e.g. albumin, casein) where they remain detectable.

Because allergen information protects health, it is one particular that cannot be pushed to the e-label — it stays on the physical pack regardless of the electronic option above.

Keep the two "sulphite numbers" distinct. The labelling trigger (whether you must write "contains sulphites") is the FIC Annex II threshold. The maximum permitted SO₂ in the wine is an oenological limit set separately by Commission Delegated Regulation (EU) 2019/934 of 12 March 2019, Annex I Part B — 150 mg/L for red and 200 mg/L for white and rosé wines released for direct human consumption, with higher ceilings for certain sweet wines and designations (CELEX 32019R0934). These maxima live in the oenological-practices regulation, not in the labelling regulation.

How Regulation (EU) 2019/33 frames wine labelling

The detailed wine-labelling and presentation framework is Commission Delegated Regulation (EU) 2019/33 of 17 October 2018 (OJ L 9, 11 January 2019), which supplements Regulation (EU) No 1308/2013 (CELEX 32019R0033). It governs protected designations of origin (PDO) and geographical indications (PGI), traditional terms, the objection procedure, restrictions of use, product-specification amendments, cancellation of protection, and labelling and presentation of wine.

In short: 2019/33 sets the structural rules for how a wine label is composed (mandatory and optional particulars, origin, terms), while 2021/2117 bolted the nutrition and ingredients obligations onto that framework via Regulation (EU) No 1308/2013. A common error is to look to 2019/33 for SO₂ maxima — those are not there; they sit in 2019/934 (oenological practices). Note also that Regulation (EU) 2019/33 is the wine-labelling delegated act; it should not be confused with unrelated instruments carrying similar numbers.

Dates at a glance

• 2 December 2021 — Regulation (EU) 2021/2117 adopted (in force the day after publication in OJ L 435, 6 December 2021).
• 8 December 2023 — nutrition declaration and list of ingredients become mandatory for wine; consolidated Regulation (EU) No 1308/2013 dated to this day.
• From 8 December 2023 onward — wine labelled before that date may still be sold until stocks are exhausted.

Claim → source mapping

• "Nutrition declaration + list of ingredients mandatory for wine" → Reg (EU) 2021/2117, amending Art. 119 of Reg (EU) No 1308/2013 — CELEX 32021R2117.
• "Applies from 8 December 2023" → consolidated Reg (EU) No 1308/2013, consolidation date 08.12.2023 — CELEX 02013R1308-20231208.
• "Energy value on-pack; full nutrition + ingredients may be electronic, no data collection/marketing" → Reg (EU) 2021/2117 — CELEX 32021R2117.
• "Existing stocks may continue until exhausted" → Reg (EU) 2021/2117, recital 42 — CELEX 32021R2117.
• "Allergens mandatory and emphasised, always on physical label" → Reg (EU) No 1169/2011, Arts 9(1)(c) & 21, Annex II — CELEX 32011R1169.
• "Wine labelling framework (PDO/PGI, presentation)" → Commission Delegated Reg (EU) 2019/33 — CELEX 32019R0033.
• "Max total SO₂ 150 mg/L red, 200 mg/L white/rosé" → Commission Delegated Reg (EU) 2019/934, Annex I Part B — CELEX 32019R0934.

References

• Regulation (EU) 2021/2117 (2 December 2021), CMO reform adding wine nutrition + ingredients — EUR-Lex CELEX 32021R2117.
• Regulation (EU) No 1308/2013, consolidated version dated 08.12.2023 (Art. 119 mandatory particulars) — EUR-Lex CELEX 02013R1308-20231208.
• Regulation (EU) No 1169/2011 (FIC, 25 October 2011), allergen rules — EUR-Lex CELEX 32011R1169.
• Commission Delegated Regulation (EU) 2019/33 (17 October 2018), wine labelling & presentation — EUR-Lex CELEX 32019R0033.
• Commission Delegated Regulation (EU) 2019/934 (12 March 2019), oenological practices incl. SO₂ maxima — EUR-Lex CELEX 32019R0934.

This is a summary, not legal advice — consult the official text and your national authority. Complements the practical MakeWine /learn/eu-labelling how-to.

Frequently asked questions

When did EU wine have to start showing nutrition and ingredients?

From 8 December 2023, under Regulation (EU) 2021/2117, which amended Regulation (EU) No 1308/2013. Wine labelled before that date may continue to be sold until stocks are exhausted.

Can I put the nutrition table and ingredients online instead of on the bottle?

Partly. The energy value must appear on the physical label, but the full nutrition declaration and the list of ingredients may be provided electronically via an e-label, provided that route collects no user data, does no tracking, and carries no marketing.

Do allergens like sulphites go on the e-label too?

No. Allergen information — including 'contains sulphites' and egg/milk-derived fining agents — must stay on the physical label under Regulation (EU) No 1169/2011 (Articles 9(1)(c) and 21, Annex II). It can never be moved off-pack.

Is a wine e-label the same as a Digital Product Passport (DPP)?

No. The DPP comes from the Ecodesign for Sustainable Products Regulation (ESPR) and does not currently cover wine. A clean, linkable wine e-label is best described as 'DPP-ready', not a DPP.

Where are the maximum SO₂ limits set?

In the oenological-practices rules, Commission Delegated Regulation (EU) 2019/934, Annex I Part B — 150 mg/L for red and 200 mg/L for white and rosé (higher for some sweet wines), not in the labelling regulations.