E-labels Master Guide
Updated: Sep 6
Learn how to fulfill the European regulations on wine ingredients and nutritional labeling.
Disclaimer
This is our best interpretation of the laws and compilation of respected legal opinions in the European Union around the nutritional and ingredient declaration for wine. Please consult legal advice from a professional for the most up-to-date information. This information is also subject to change.
“In order to provide a higher level of information to consumers, the compulsory particulars…. should include a nutrition declaration and a list of ingredients. However, producers should have the option of limiting the contents of the nutrition declaration on the package or on a label attached thereto to only the energy value and of making the full nutrition declaration and the list of ingredients available by electronic means, provided that they avoid any collection or tracking of user data and do not provide information aimed at marketing purposes.”
Requirements for E-labels
For any wine sold in the EU, you must provide:
List of ingredients
Nutrition information
Attention: If wines can be directly ordered by the end consumer on a price list, brochure, flyer, online shop, etc. (e.g., by phone, in writing, by fax), the ingredient list and nutrition information must also be provided.
8th of December 2023
The regulation applies to wines produced on and after the 8th of December 2023 for sale in the EU.
There is no clear definition of "produced" in the legislation. Practically, many legal experts think 2024 will be the first vintage that will be regulated.
Producers have started to comply. Bottlebooks is offering forever discount codes so that any additional cost to start early will be recovered over time.
Be aware that retailers, importers, and customs officials are likely to be gatekeepers requiring compliance earlier, so it is important to talk to your distribution partners.
For imported products, VI-1 document and VI-2 extracts will require the list of ingredients.
For bulk wine, the list of ingredients must be included in the accompanying documentation through the lifecycle from the producer, bottlers, processors, and finally to the merchants.
Spirits are expected to follow soon.
Using E-labels (Qr codes)
The full nutritional table list of ingredients can be available through an e-label - a QR code on the printed label that links to a mobile webpage.
There are a number of conditions that the e-labels must meet whether you use your website or a third-party supplier such as Bottlebooks.
Translated. The labels need to be translated into the languages of any country you might sell in using the official EU translations.
Lasting. Your e-labels must last as long as the wine is sold.
No user data may be collected. That means no tools such as Google Analytics. (Only location is allowed to be collected in order to deliver the appropriate language.)
No sales. No marketing or selling your wines is allowed.
No downloads. There should be no PDF or other downloads.
No navigation. The user should not have to click to get to another page with the information. Note: there is one source of legal advice that is suggesting navigation might be allowed. We will clarify if we know more.
What if I just put the information on my website?
You are allowed to, however you must just meet all the conditions above. For most producers, this will be unrealistic and more costly than using a third party solution as it will require setting a separate website infrastructure from your marketing website and online store.
Bottlebooks E-labels
We built Bottlebooks E-labels with consultation of compliance teams and managers from producers large and small. We aimed to make the most producer friendly, easy-to-use, legally compliant system.
Bottlebooks E-Labels:
Complies with the EU legislation
Uses official EU translations to automatically translate to all EU languages
Lets you use your Bottlebooks data
Includes Italian recycling package requirements
Does not charge for older labels raising your subscription price over time
Allows you to switch away from Bottlebooks to your website or another provider at anytime
Bottlebooks is the largest wine product data network in the world. Our clients include the largest 20 producers, ProWein, California, Spain, Waitrose, and Ahold group.
You can create 3 free e-labels today (no commitment or credit card required) on Bottlebooks
https://elabels.bottlebooks.me/elabels
Other Providers
This guide will refer to and use Bottlebooks E-labels to help you get compliant, however there are a number of other e-label providers. We have not tested and verified these services. It is likely some of them will not comply with the legislation, so please do your own research.
Members of the SAFE E-label group with Bottlebooks: https://safe-elabel.org/
Advanced Track and Trace Track and trace technology leaders
Dans ma Bouteille Dedicated to ingredient transparency with wine
Vin.co Sales and marketing solutions for wineries
Other providers
Digilabel A South African industry solution
Flabel A collaboration of Artify and Euvinopro
Scantrust Track and trace platform
Ulabel A recently founded e-labels only company
Get Started
Follow the link below to create 3 free e-labels today on Bottlebooks (no commitment or credit card required).
https://elabels.bottlebooks.me/elabels
After you sign in or sign up follow the instructions to create your first E-label. You can find more in our guide: https://bottlebooks.freshdesk.com/support/solutions/articles/19000139111-how-to-create-e-labels-guide
Through this process you will be guided to create a compliant e-label. There are five main components of the e-label that you will complete:
Product identification
Ingredients list
Nutritional values
Packaging
Optional information
Product identification
It is recommended that you create a new e-label for every:
new product
new size
new vintage
In future, the QR code is slated to replace the barcode to be scanned at checkout.
Note: There are some differing opinions on this. There is some respected legal advice that states that as long as the information is correct, multiple products can use the same QR and e-label. We will update this guide as we get clarification.
Caution: once an e-label is in the market, you should not update it unless the information needs to be corrected. For instance do not use the same e-label for the new vintage by updating the information on the old vintage e-label. This will result in non-compliance with the old vintage.
Ingredients
Bottlebooks uses the official EU ingredients in our ingredients picker. Our system will format your list to meet the legislation. For example, Bottlebooks will bold allergens to differentiate them from the other text.
When picking the ingredients, there are a few rules you need to be aware of.
You are able to use either the proper ingredient name or the corresponding E number.
For “grape must” you should use “grapes”.
For “rectified concentrated grape must” you should use “concentrated grape must”.
The terms "tirage liqueur" and "shipping liqueur" may also be indicated without further specification of the individual ingredients.
You are allowed to add three ‘acidity regulators’ and ‘stabilising agents’ as long as one is used in the process. Bottlebooks will group them in a “contains” as statement according to the regulation.
If multiple wines are blended, it is recommended to list all used ingredients in total (e.g., mention sugar, tartaric acid, or sulfur dioxide only once in the list).
Ingredients must be listed in descending order of weight as they were used during the manufacturing of the food. Ingredients that make up less than 2% of the finished product may be listed in any order, after the other ingredients. Refer to ANNEX VII of EU 169/2011. Click on the six dots next to any ingredient and drag and drop to reorder.
Certain additives used as packaging gasses (carbon dioxide, argon and nitrogen) have as a main objective the displacing of oxygen during the bottling of grapevine products,
but they do not become part of the product that is consumed. In these cases you can choose to add “Bottled in a protective atmosphere” or “Bottling may happen in a protective atmosphere”.
Nutritional Label
You may use the Bottlebooks calculator or manually enter your own data.
Bottlebooks use the following formula to calculate energy.
kcal = ((7.9 x alcohol) x 7) + (residual sugar x 4) + (total acidity x 4)
In Bottlebooks, if you have entered residual sugar previously we will automatically use this calculation: for 10 g/l of residual sugar , we set 1 g /100ml of carbohydrates and 1 g /100ml of sugars.
Guidelines expressing “0g” for negligible amounts of fat, saturates, protein and salt can be found in section 6, table 4 of the EU guidance documents on nutritional labeling for EU 1169/2011 among others. You are responsible for declaring values that exceed these tolerances, however many associations and legal experts are declaring that for typical wines no additional test is necessary.
The allowable tolerances are harmonized within the EU. Therefore, for wines with a sugar content below 100 g/l (typically all wines except sweet wines), a tolerance of 2 g/100 ml (equivalent to 20 g/l) is allowed for the declaration of sugar/carbohydrates.
Packaging
It is required in Italy to indicate the material identification code on your packaging and provide the waste collection guideline according to Decreto legislativo 3 aprile 2006, n. 152.
This can be entirely done through the Bottlebooks e-label by searching for and selecting the materials you are using.
Note: Packaging is rumoured to be coming soon to other EU countries.
Optional Information
There are a variety of optional information you are permitted to add to your e-label.
This includes:
Certifications
Your logo
A link to your main website (not your online store)
Varietals
Alcohol
Responsible consumption
Food business operators
In any of these cases, if you put the information on the e-label, it does not exempt you from also putting it on the label when required.
Designing the back label with a QR code
There is no stated language in the regulations that determine how you should display the QR code. Some legal experts are recommending adding an “i” to the middle of the QR code (this is a downloadable option in Bottlebooks, click on "Customize" next to any QR code) or adding text nearby such as "Ingredients and nutritional values". All this information needs to be grouped together.
It is critical you ensure your QR code is printed properly. We have created a separate guide for you:
Note: For all grapevine products that have undergone a de-alcoholisation treatment and have an actual alcoholic strength by volume of less than 10% it is appropriate to establish the date of minimum durability on the label.
Printed label with no QR
For printed labels with no QR code, you can use Bottlebooks to create your own ingredient and nutritional values.
Simply follow the steps above to complete the information in Bottlebooks. You can then copy and paste the ingredients list and, after publishing, you can go to the downloads tab in the product to copy out the nutritional table.
Note: some legal guides state that you can use the statement “contains negligible amounts of fat, saturated fat, carbohydrates, protein and salt” to replace stating those values in the table.
Links
Learn more: https://www.bottlebooks.me/e-labels
Get started: http://elabels.bottlebooks.me/
FAQ: https://www.bottlebooks.me/post/e-label-faq
Simple Guide and Infographic: https://www.bottlebooks.me/post/a-simple-e-label-guide
The Main EU Regulations
(EU) delegated regulation to 2021/2117 and 1169/2011
A draft of the legislation that has been adopted
Outlines the use of electronic labels to deliver nutritional and ingredient information.
Ingredients names and terms are contained here
Decreto legislativo 3 aprile 2006, n. 152
Italian recycling regulations
Guidance document for 1169/2011
Set the tolerances for nutritional values