Regulation of wine labeling in the EU
Recent clarifications and harmonization have been made to the European regulation of wine labeling, a fundamental subject in the law of wine.
For the protection of the consumer, the labeling of wines is strictly regulated by law. The label must provide accurate and honest information about the product.
Thus, in order to market its wine in France and throughout the European Union, producers must comply with the rules on the presentation and labeling of wines.
The legislator distinguishes between compulsory information, which must appear on the front label of the wine, and optional information, which can be placed on the back label.
The compulsory information
The following is a list of the labeling requirements provided for in Article 119 of the Rules of Procedure of the European Parliament and of the Council No. 1308/2013 and in Articles 40 and following of the new Commission Regulation No. 2019/33 of 17 October 2018 which entered into force on 14 January 2019 :
- - 9 mandatory statements ;
- - the statements must be included in the same visual field on the cylinder so that they can be read simultaneously without the need to rotate the container (except for the lot number and allergenic ingredients) ;
- - the size of these statements must be at least equal to 1.2 mm
The mandatory indications of the lot number and the allergenic ingredients, however, may appear outside the visual field in which the other mandatory indications appear.
The 9 required statements are listed below :
1) The name of the product category of the vine
It is obligatory to mention the product category of the wine, that is : wine, sparkling wine, new wine still in fermentation, liqueur wine…
For wines with an AOC or AOP, this indication may be replaced by the words "appellation d’origine contrôlée" or "appellation d’origine protégé" completed with the name of the geographical region. For wines with PGI, “Protected Geographical Indication” is followed by the name of the designation.
2) Acquired Alcohol Density Titles (TAVA)
The alcoholic strength by volume is expressed in units or half units of percentage and is represented by the symbol "% vol". It may be preceded by the indication "actual alcoholic strength" or "alcohol acquired” or the abbreviation “Alc.”.
The title displayed on the cylinder shall not be more than 0.5% vol. or less than the title determined by analysis.
The size of the characters must be at least :
- - 5 mm high if : nominal volume > 100 cl,
- - 3 mm high if : 20 centilitres nominal volume 100 cl
- - 2 mm high if : nominal volume less than or equal to 20 cl.
3) Indication of provenance
For wines with an AOC, AOP or IGP, the name of the country of origin must appear on the label : « wine of France », « produced in France « product of France ».
In the case of wines without geographical indication, the provenance must be indicated in the sales description "wine of France", "Wine of the EU" or in addition "produit en/au/aux/à..." or “product of/of/d’…”.
4) The nominal volume
The label must indicate the volume of the bottle of wine. For each category of wine, a range of usual volumes is defined. The wines must be marketed in the following volumes : 125, 200, 375, 750, 1500 ml.
5) Bottler name and address
The information about the bottler (name and address) must appear on the label and is supplemented by the words “bottler” or “bottled by…”.
6) The batch number
The lot refers to a set of sales units of a food product produced, manufactured or packaged under virtually identical circumstances. The lot number consists of numbers and/or letters preceded by the capital letter “L”, unless it is clearly distinguishable from other labeling.
7) The Allergens
If the wine contains ingredients likely to cause adverse reactions to the consumer, the label must state “contains” (in French or another European Union language) followed by the following allergens :
- - Sulphites
- - Milk and eggs and their derivatives
8) The health message
In France, alcoholic beverages (with a concentration of more than 1.2% vol.) marketed must include on the label a health message intended for pregnant women advocating non-consumption of alcohol during pregnancy, such as : “The consumption of alcoholic beverages during pregnancy, even in small quantities, can have serious consequences for the health of the child”, or a pictogram representing a pregnant woman in a barred circle.
9) The sugar content
This indication is compulsory only for sparkling wines, sparkling carbonated, of quality or of aromatic quality, which may use the following terms depending on the sugar content :
- - Natural gross : less than 3 g/L
- - Extra gross : content included
- - Gross : less than 12 g/L
- - Extra dry : content between 12 and 17 g/L
- - Dry : content between 17 and 32 g/L
- - Half-dry : content between 32 and 50 g/L
- - Soft : content greater than 50 g/L
A margin of error of 3 g/L between the displayed content and the actual content is allowed.
Optional statements are additional statements that do not necessarily have to appear on the label, but are regulated. They are provided for in Article 120 of the Regulation of the European Parliament and of the Council No. 1308/2013 and are regulated in Articles 49 and following of the new Commission Regulation No. 2019/33 of 17 October 2018.
1) Vintage and grape variety
The mention of the vintage requires that at least 85% of the grapes used to produce the wine have been harvested during the year in question.
The mention of the grape variety requires that the wine comes from at least 85% of the grape variety concerned. If the name of two or more grape varieties is used, the wine must come from 100% of these varieties and the grape varieties must be indicated in descending order of the proportion used.
The terms initially reserved for wines benefiting from AOC/AOP or IG are now open to wines without geographical indication, subject to specific certification (Art. 50 of Regulation (EU) No 2019/33).
2) Sugar content of non-sparkling wines
While this is required for sparkling and sparkling carbonated wines, it is optional for other wines. For example, the following is mentioned :
- - Dry : less than 4 g/L
- - Half-dry : less than 12 g/L
- - Sweet : content between 12 g/L and 45 g/L
- - Sweet : content greater than 45 g/L
3) Traditional mentions
Traditional terms are used to denote a particular quality or seniority of the product. They are reserved for wines benefiting from AOC/AOP or IGP.
In France, for example, the following terms are used : “château”, “hospice”, “Clairet”, “clos”, “cru bourgeois”, “primeur”, “village”, “AOC”, “vin de paille”.
4) Reference to production methods
The wines marketed within the European Union may refer to certain production methods which refer to fermentation, maturing or aging of the wine : « aged in oak barrels », « manual harvesting », “old vines”, “traditional method” for sparkling wines, etc…
Where the wine has been matured or aged in a wooden container for at least six months, and for half of the volume in question, the following statements may be used : "aged in drums" / "aged in drums of ..." , “fermented in barrels”, “fermented in barrels of…”, or “aged in barrels” or “aged in barrels of…”.
5) Geographical Indication
Wines with an AOC/AOP or GI, may use the name of a geographical area that is smaller or larger, if their specifications permit.
6) The name of the operation
The reference to a holding (Château, Domaine, Clos, Mas, etc.) is reserved for wines under AOC/AOP or IGP. The wine must be produced exclusively from grapes harvested in the vineyards operated by this holding. The winemaking must be carried out entirely in the holding.
7) Qualitative symbols
The symbols relating to the AOC/AOP and the GI may be used in the form of the following logos, together with the name of the geographical indication.
With regard to organic wine, if the producer meets the criteria for organic viticulture, he can use the EU organic logo or the logo corresponding to the collective certification mark « Organic Agriculture » existing in France :
Finally, the awards or medals obtained during wine tastings taking place in France may be featured on the label.