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Key Regulations Texts and References

We have compiled the regulation texts and some key information about declaring ingredients and nutrition for wine and aromatised wine products. 

 

As a food operator, you remain responsible for the food information that you declared. This document serves as a guideline to help you kick start with the declaration. For the most accurate interpretation of the regulations, please refer to the original texts and your law advisor. 

 

Relevant regulation

(EU) 2021/2117

This regulation amends four EU Regulations (1308/2013; 251/2014; 1151/2012; 228/2013) and specifies the need for a nutrition declaration and list of ingredients, and the option to present them by electronic means identified on the package or on a label attached thereto.

 

(EU) 1308/2013

This regulation established a common organization of the markets in agricultural products and included specific labeling rules for the provision of food information on wine products.

You can find the mandatory particulars and rules for wine labeling, and the list of grapevine products which mandatory labeling applied.

 

(EU) 1169/2011

The horizontal regulation that specifies the general rules and principles on food information to consumers.

 

(EU) 2019/33

Supplements to (EU) 1308/2013. It has been amended by (C)2023/3257 that provides detailed rules on declaring ingredients, such as the term to be used for the name of specific ingredients.

 

(EU) 2019/934

This regulation provides the list of additives and processing aids, with their functional categories, name, and E number that shall be used to declare in the ingredient list. 

 

Corrigendum to (EU) 2021/2117

Update to (EU) 2021/2117 that the wine that are produced before 8 December 2023 does not need to declare the ingredients and nutrition.

Overview

  • (EU) 2021/2117 mandates the full declaration of nutrition and ingredients shall be provided for wine and aromatised wine products and this can be done via electronic means, provided that no user data are collected or tracked and no marketing or sales information are displayed. 
  • The labeling of grapevine products can be supplemented by (EU) 1169/2011 (Article 118 of (EU) 1308/2013). Thus we may refer to (EU) 1169/2011 for the rules and principle of declaration where (EU) 1308/2013 has not been mentioned.
  • If 

Grapevine product category

  • According to Article 119 of (EU) 1308/2013, the grapevine product that has to be labeled with the mandatory particulars are points 1 to 11, 13, 15 and 16 of Part II of Annex VII
    • 1. Wine
    • 2. New wine still in fermentation
    • 3. Liqueur wine
    • 4. Sparkling wine
    • 5. Quality sparkling wine
    • 6. Quality aromatic sparkling wine
    • 7. Aerated sparkling wine
    • 8. Semi-sparkling wine
    • 9. Aerated semi-sparkling wine
    • 10. Grape must
    • 11. Partially fermented grape must
    • 13. Concentrated grape must
    • 15. Wine from raisined grapes
    • 16. Wine of overripe grapes
  • The grapevine products under Annex VII, Part II, point (1) and points (4) to (9) that have undergone a de-alcoholisation treatment shall be accompanied by the term “de-alcoholised” or “partially de-alcoholised” (Amendment to 1(a) of Article 119, (EU) 2021/2117)
    • 1. Wine
    • 4. Sparkling wine
    • 5. Quality sparkling wine
    • 6. Quality aromatic sparking wine
    • 7. Aerated sparkling wine
    • 8. Semi-sparking wine
    • 9. Aerated semi-sparking wine

“De-alcoholised” - the actual alcoholic strength of the product is no more than 0,5% by volume

“Partially de-alcoholised” - the actual alcoholic strength of the product is above 0,5% by volume and is below the minimum actual alcoholic strength of the category before de-alcoholisation. 

Ingredient declaration

  • The list of ingredients must contain any substance or product used in the manufacture or preparation of a food and still present in the finished product, even if in an altered form. Residues are not ingredients This includes: 
    • Flavorings
    • Food additives
    • Food enzymes, except for those used as processing aids 
    • Any constituent of a compound ingredient
    • Processing aids that cause allergies and intolerances

(Article 1, 2(f) of (EU) 1169/2011)

  • The ingredient list shall be headed by the term containing “ingredients”. (Article 18 of (EU) 1169/2011)
  • Ingredients have to be declared in descending order of weight of food (Article 18 of (EU) 1169/2011), except when the ingredients are less than 2% of the product, it can be declared in a different order after other ingredients. (Annex VII, Part A, (EU) 1169/2011)
  • References & rules for the name of the ingredients 
    • “grapes” may be used to replace fresh grapes and/or grape must used as the raw material (Article 48a of (c)2023/3257)
    • “Concentrated grape must” may be used to replace concentrated grape must and/or the rectified concentrated grape must (Article 48a of (c)2023/3257)
    • The oenological compounds categories, names and E numbers must used the list in  Annex I, Part A, Table 2, of Delegated regulation (EU) 2019/934 (Article 48a of (c)2023/3257)
    • The oenological compounds that cause allergies or intolerances refers to column 1 of Table 2 of Part A of Annex I to Delegated Regulation (EU) 2019/934.
    • Substances that cause allergies or intolerances, concerning sulphites/ sulfites, eggs and egg-based products, milk and milk-based products, the terms for labelling are provided in Annex I, Part A of (EU) 2019/33.
    • Other substances or products that causes allergies or intolerances refers to Annex II of (EU) 1169/2011
  • Declaring the ingredients that cause allergies or intolerances
    • When the ingredient list is declared on the label, the ingredients that cause allergies and intolerances have to be part of the ingredient list, with its name emphasized through a typeset that clearly distinguishes it from the rest of the ingredients (font, style, background colour etc.) (Article 21 of (EU) 1169/2011)
    • For the ingredient list that have been declared via electronic means, the ingredients that cause allergies or intolerances must appear in the ingredient list with distinguishable typeset, as well as on the physical label, however due to the absence of ingredient list on the physical label, when declaring, use the word “contains” followed by the name of the ingredients (Article 21(1)(b) of (EU) 1169/2011)
    • There are 3 references for the name of the ingredients that cause allergies and intolerances
      • Annex I, Part A of (EU) 2019/33 for the terms concerning sulphites/ sulfites, eggs and egg-based products, milk and milk-based products
      • Column 1 of Table 2 of Part A of Annex I to Delegated Regulation (EU) 2019/934 for the oenological compounds that cause allergies or intolerances
      • Annex II of (EU) 1169/2011 for other substances and products that cause allergies or intolerances
  • Declaring additives 
    • Additives have to be declared with their functional category in the form of Category (Ingredient 1, Ingredient 2…) or Category (E number 1…). (Annex XI, Part C of (EU) 1169/2011).
    • In the case where the additive belongs to multiple categories, declare it in the category which represents its principal function in the food  (Annex XI, Part C of (EU) 1169/2011).  
    • The name of the functional categories, ingredients and their E-number is given in Annex I, Part A, Table 2 of (EU) 2019/934.
    • For additives under the category of “acidity regulators” and “stabilising agents” which are similar or mutually substitutable,  they can be indicated with the expression <contains…and/or>, followed by no more than three additives, where at least one is present in the final product. (Article 48a of (C)2023/3257)
  • Declaring processing aids
    • Processing aids only need to be declared if they cause allergies and intolerances (Article 20(b) of (EU) 1169/2011). For example, yeast and bacteria are processing aids, so if they do not cause allergies or intolerances, they do not need to be declared. 
    • Food enzymes that are used as processing aids can be excluded from the ingredient list (Article 20 of (EU) 1169/2011)
  • Declaring packaging gases
    • Packaging gases are additives (Annex I, Table 2, (EU)2019/934), so they have to be declared in the ingredient list if they are used for the manufacture of the grapevine product and present in the 
    • When declared in the ingredient list, their functional categories, name and E number have to refer to Table 2, Annex I of (EU) 2019/934.
    • The declaration of packaging gases may be replaced with the the specific particular ‘Bottled in a protective atmosphere’ or ‘Bottling may happen in a protective atmosphere’. (Article 48a of (C)2023/3257)
  • Declaring substances used for enrichment and sweetening 
    • Sucrose, concentrated grape must, and rectified concentrated grape must are ingredients and are therefore part of the list of ingredients.
    • Concentrated grape must and rectified concentrated grape must can be presented by the term “concentrated grape must”

(Article 48a of (C)2023/3257)

  • Declaring “triage liqueur” and “expedition liqueur”
    • The terms “tirage liqueur” or “expedition liqueur” may be displayed in the list of ingredients, either alone or accompanied with a list of their constituents in a bracket, referring to Annex II of (EU) 2019/934 (Article 48a of (C)2023/3257)
  • Specific rules for aerated sparkling wine, aerated semi-sparkling wine and quality sparkling wine
    • The terms “aerated sparkling wine” and “aerated semi-sparking wine” have to be supplemented in characters of the same type and size by the words “‘obtained by adding carbon dioxide’ or ‘obtained by adding carbon anhydride’, even where Article 119(2) of Regulation (EU) No 1308/2013 applies. (Article 48 of (EU) 2019/33)

Nutrition declaration

  • The mandatory nutrition declaration are
    • Energy value
    • Amounts of fat, saturates, carbohydrate, sugars, protein and salt

(Article 30 of (EU) 1169/2011)

  • The energy value and the amount of mandatory nutrients have to be expressed per 100g or 100 ml. (Article 32 of (EU) 1169/2011) Expression per consumption unit or portion is optional. (Article 33 of (EU) 1169/2011)
  • The energy value and the amount of mandatory nutrients have to be in the unit of measurement in Annex XV, 1169/2011. (Article 32 of (EU) 1169/2011)
  • The energy value and amount of mandatory nutrients shall be those of the food as sold. 
  • The declared value of energy and amount of mandatory nutrients are average value based on:  
    • The manufacturer’s analysis of the food;
    • A calculation from the known or actual average values of the ingredients used; or
    • A calculation from generally established and accepted data.

(Article 31 of (EU) 1169/2011)

“Average value” is the value which best represents the amount of the nutrient which a given food contains, and reflects allowances for seasonal variability, patterns of consumption and other factors which may cause the actual value to vary. (Annex I of (EU) 1169/2011)

Tolerances allowed can refer to this guidance document.

  • The energy value and the amount of mandatory nutrients shall be presented in tabular format with the numbers aligned and in the order of presentation as of Annex XV of (EU)1169/2011 . Only when space is not permitted, can it appear in linear format. (Article 34 of (EU) 1169/2011)
  • Specific rules for energy value
    • Energy value shall be calculated based on  the conversion factors listed in Annex XIV of (EU) 1169/2011.
    • When declaring the nutrients in electronic form, the energy value has to be declared on the physical label as well, expressed with the symbol “E” for energy. (Article 116a of (EU) 2021/2117)
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