Changing regulations in the European Union may forever alter how wine and spirits brands label their products in current and upcoming years.

While alcoholic beverages were typically exempt from a rule that requires all food and beverage products to have a nutritional label, this is no longer the case. An upcoming change may also require brands to add additional warnings about alcohol — but that is not yet in effect.

There are many proposed regulations — and some that are in limbo — so it can be confusing trying to determine what is merely a proposal from what is a true requirement.

EU Wine Labeling Requirements

By December 2023, all labels on wine sold in the EU are required to have nutritional information.

The new requirement dictates that only the energy value (dictated by an “E” and similar to a calorie count) be listed on the physical wine bottle label. Other required information — including full nutrition and ingredients — can be listed electronically with a QR code or other means. 

The regulation comes with a few stipulations:

1. Ingredients causing allergies and intolerance are required to be on the physical label.
2. The electronic labels may only contain the required information — no content for sales or marketing purposes is allowed.
3. These electronic labels cannot collect or track user data.

This requirement falls under EU Regulation 2021/2117 of the EU reform’s Common Agricultural Policy. It amends the Aromatised Wine Products Regulation (EU) No 251/2014 and, therefore, applies to wine and aromatized wine products. Read the original regulation for all stipulations.*

How Brands Can Comply with Wine Labeling Requirements

As noted above, the regulations will be strict about the type of electronic labels that can be used, since there can be no marketing, sales or data tracking. This would disqualify most brand websites, which contain marketing and sales information as well as, usually, analytics tracking.

While brands may be forced to use a separate site to comply with these regulations, they can use the QR code that leads to these sites to their advantage in other ways. Below are a few ways they may be able to do that.

Direct to the QR Code to a Different Site Outside of the EU

Brands using the Blue Bite Connected Products Platform can direct consumers to different sites based on location. A consumer scanning in the EU will be directed to a site with no tracking or marketing information. A consumer scanning the same product in England — using the same QR code so there’s no need for different codes in different areas — can be directed to a Blue Bite personalized mobile experience that opens a direct, two-way communication channel between brand and consumer.

Let’s talk and determine how your brand can get in compliance while also not losing connections with consumers. 

An Opportunity for Wine Brands Based Outside the EU

The EU regulation requires any wine sold in the EU to be compliant. Using a Connected Product Platform to determine where a product is scanned also works for brands that are not based in the EU, but sell products there. 

These non-EU wine makers can provide the app-like mobile website built in the Blue Bite Experience Studio that consist of content and features (such as images, videos, forms and functionality) that can each be optimized with logic to consumers outside of the EU. For those that scan in the EU, they can provide a link to a different, compliant website — all with the same QR Code.

Do the EU Wine Label Regulations Apply to Spirits & Beer

The current regulation only applies to wine, but many innovative Wine, Spirits & Beer brands are working to get ahead of any similar legislation that may come to Spirits and Beer. 

Leveraging a Blue Bite Connected Products strategy sets your brand up for any regulation that may come. Blue Bite personalized experiences empowers brands to quickly and easily update any messaging — or QR links — by product, location and much more right in the platform. 

Other Alcohol Label Regulations and Requirements

Upcoming regulations could require all alcohol labels to have nutrition information.

EU’s Beating Cancer Plan

The European Union’s Beating Cancer Plan had initially outlined that there should be a proposal for all alcoholic beverages to have ingredients and nutrition information on the label by the end of 2022. By 2023, they were slated to implement health warnings about the possible effects of drinking alcohol.

Lawmakers voted against including alcohol warning labels in February 2022.

Where it stands

It’s expected the Commission will have a proposal for all alcohol labels by the end of 2023. From there, it would take more time until it’s adopted into a complete regulation. Similar proposals have taken around 1-2 years from the time they are accepted until they are implemented.

Ireland’s 2018 Public Health (Alcohol) Act

A new regulation in Ireland could require all alcohol in the country to have health warnings stating that “drinking alcohol causes liver disease, harms the unborn baby, and is directly linked to fatal cancers,” Politico reported.

Similar to those on packages of cigarettes, these warnings would appear on the label itself or on a sticker on the bottle.

Many other European countries have pushed back against this regulation, which comes from an EU approval of a section of the 2018 Public Health (Alcohol) Act. Critics say the proposed label regulation does not accurately distinguish between “moderate” and “excessive” consumption. Others feel it pits the public interest against wine and spirits makers.

Nonetheless, if it’s adopted, it would require all alcoholic beverages sold in Ireland to bear the label.

Where it stands

While this is currently up for legislation, it is merely a proposal and not yet a definite requirement. It may also never reach the point where it is a requirement. The attorney general’s office is working to refine the document, and it must be signed by Ireland’s Health Minister, Stephen Donnelly. From there, there is a planning period that lasts a minimum of three years — so the earliest this change may happen is 2026.

France’s AGEC

France has adopted anti-waste laws, formally under the Anti-waste Law and the French Roadmap for a Circular Economy. 

As part of the regulations, France aims to have single-use plastic packaging phased out by 2040. By 2025, the country aims to have 100% of plastics be recyclable. Brands must also be more transparent about the durability and environmental impact of their products.

Companies must make a sheet detailing environmental qualities or characteristics available to consumers via web search at the time of and post-purchase. This information should be easily accessible, reusable, and on a dedicated web page for at least two years after the final unit of the product is brought onto the market. This includes information like recyclability, compostability, sustainability, the presence of recycled materials, the presence of any hazardous substances and more.

Regarding brand and product labels: Under this law, brands can not claim products or packaging is "biodegradable," "environmentally friendly” or any similar term.

Where it stands

The requirement that brands cannot make environmental claims about their products formally went into effect as of January 1, 2023.

The regulation requiring companies to be transparent about their products applies on a rolling basis:

• January 1, 2023: Applies to producers with a turnover of >50 million euros and 25,000 product units on the market yearly
• January 1, 2024: Applies to producers with a turnover of >20 million euros and 10,000 product units on the market yearly.
• January 1, 2025: Applies to producers with a turnover of >10 million euros and 10,000 product units on the market yearly.

Italy’s Mandatory Labeling Requirements for Packaging

As of January 1, 2023, companies must adhere to guidelines dictating how products are labeled and packaged in Italy. This applies until all existing stocks of the product are sold.

This falls under the Mandatory Labeling Requirements for Packaging law, which outlines how companies must label their products. It can be done with a QR code, which makes it easy for brands to convey this information to consumers.

All packages are required to have:

• An alphanumeric code indicating the packing material family
• Collection guidelines, showing how the product can be recycled, etc.

There is also optional labeling that can help brands be more transparent with consumers. This generally includes:

• Type of packaging (materials)
• UNI (Italian) standards with supplementary information
• Information to help citizens with local guidelines that is not directly required

While these are the general guidelines, the specific requirements change depending if the product is B2B or B2C, if the packaging consists of several components that cannot be separated by hand and if the packaging has elements that can be separated by hand.

*Note that none of the information within this article is legal advice, and there is no guarantee of accuracy of the information, as these regulations and requirements are continuing to evolve. Check the original sources for the latest updates on all information.