Starting December 8, 2023, all wines produced in or imported to the European Union must provide nutritional information and ingredient lists to consumers. Regulation (EU) 2021/2117 amended the previous Common Market Organisation (CMO) framework and introduced the electronic label — commonly called the e-label — as the primary mechanism for delivering this information.
If you produce wine, this regulation affects you. Whether you are a small estate in Bordeaux, a cooperative in Tuscany, or an Argentine bodega exporting to Germany, the rules are the same at the point of sale within the EU.
What the regulation requires
Before 2021/2117, wine was exempt from the EU's food information requirements. Bottles only needed basic details: alcohol content, volume, origin, and allergen declarations (sulfites). Nutritional values and full ingredient lists were not mandatory.
The new regulation changes this:
Nutritional declaration — energy value (in kJ and kcal), fat, saturates, carbohydrates, sugars, protein, and salt. These values must correspond to the actual wine in the bottle, not generic averages.
Ingredient list — every substance used during winemaking that remains in the final product, including processing aids. This includes grape must, sulfur dioxide, tartaric acid, yeast nutrients, fining agents (if residues remain), and any sweetening agents.
Allergen information — sulfites, milk derivatives, egg derivatives, and any other allergens present must be highlighted.
How the e-label works
The regulation allows producers to provide nutritional and ingredient information via an electronic means — typically a QR code on the physical label that links to a web page. This is the e-label.
The e-label page must:
- Be accessible without requiring an app download or registration
- Display information in at least the language of the country where the wine is sold
- Not contain any commercial content or marketing material on the same page as the mandatory information
- Remain available for the expected lifetime of the product
- Be machine-readable (structured data is recommended)
The physical label must still display:
- Energy value per 100 ml (can use the "E" symbol)
- A QR code or URL linking to the full e-label
- The word "ingredients" or the ingredients symbol next to the QR code
Who must comply
All wines placed on the EU market after December 8, 2023 are subject to the regulation. This includes:
- EU producers selling domestically or across member states
- Non-EU producers exporting to the EU
- Wines produced before the deadline but labeled (bottled with final label) after it
- Bulk wine shipped to the EU for bottling
Wines labeled before December 8, 2023 may continue to be sold with old labels until stock is depleted.
Important for non-EU wineries: If you export to the EU, your importer will require e-label compliance. Many importers have already made this a condition of purchase orders. Non-compliant wines face rejection at customs or removal from retail shelves.
Deadlines and enforcement
The regulation took effect on December 8, 2023 for wines produced from grapes harvested from the 2023 vintage onward. Enforcement varies by member state, but most EU countries are now actively checking compliance during market surveillance inspections.
Penalties differ by country:
- France — DGCCRF can issue fines and withdrawal orders
- Italy — ICQRF conducts inspections with administrative sanctions
- Germany — state food safety authorities handle enforcement
- Spain — AICA and regional authorities oversee compliance
In practice, the biggest immediate risk is not a government fine — it is your importer or retailer refusing to accept non-compliant stock.
What data you need to prepare
For each wine (each SKU with a distinct label), you need:
- Nutritional analysis — laboratory results for energy, fat, saturates, carbohydrates, sugars, protein, and salt per 100 ml
- Complete ingredient list — documented from winemaking records: every substance added during production
- Allergen identification — flag any allergens present (sulfites, casein, albumin, isinglass residues)
- Multi-language support — the e-label page must display in the language of each target market
This requires your cellar book and laboratory records to be connected. If your winemaking data lives in paper notebooks and your lab results in a separate spreadsheet, generating accurate e-labels is a manual, error-prone process for every vintage.
How Cepaos solves e-label compliance
Cepaos tracks every operation in the cellar book — grape reception, additions, treatments, fining, blending, bottling. Every substance added to a lot is recorded with quantities and dates.
When you generate an e-label in Cepaos:
- Ingredients are extracted automatically from the lot's production history
- Nutritional values are linked from laboratory analysis records
- Allergens are flagged based on fining agents and additives used
- Multi-language pages are generated for each target market (ES, EN, FR, IT, DE, PT)
- QR codes are generated for each SKU, ready for your label printer
- The e-label URL remains stable across vintages — update the data, keep the same QR
No manual data entry. No risk of listing an ingredient you did not use or omitting one you did.
Practical steps for wineries
- Audit your current labels. Identify which SKUs are already compliant and which need updating.
- Connect your cellar book to your lab data. The e-label requires both production records and analytical results.
- Generate e-labels per SKU. Each distinct wine needs its own e-label page.
- Test the QR code. Scan it from a phone. Verify the page loads, displays correctly, and shows the right language.
- Brief your importer. Share the e-label URLs so they can confirm compliance before shipment.
Start now
The deadline has already passed. Every bottle you produce today needs an e-label before it reaches an EU shelf. The longer you wait, the more vintages accumulate without compliant data.