Pointless EU loophole outlaws millions of wine labels

An unnecessary EU loophole, which was made public late, threatens to outlaw a few million wine labels already printed and placed on the market on the bottles themselves, in an example of what does not, and cannot, work in the EU

Indeed, wines are missing the words ‘ingredients’ under the QR code that refers to the so-called e-label, the electronic label containing the list of ingredients used in the production of the wine and its nutritional values, as reported by the business newspaper ItaliaOggi.

Following the provisions of EU Regulation 2021/2117, published on 6 December 2021, European wine companies had to update their labels to meet the new mandatory requirements on the list of ingredients and nutritional declaration of wines and aromatised wine products. Yet another bureaucratic burden that adds nothing to the previous rules, apart from new costs for companies.

This information, according to EU regulations, can also be made available to the consumer online (e-label) via a QR code sticker on bottle labels.

Well, yesterday, two weeks before the entry into force of these obligations, imposed as of 8 December 2023, the European Commission published in the Official Journal of the EU (C series of 24/11/2023) the guidelines on the implementation of the wine labelling provisions of the 2017 Regulation (Communication No. C/2023/1190).

Point No. 38 of the guidelines states that: “mandatory food information” must be “affixed in a conspicuous place”, so as “to be easily visible, clearly legible, and, where appropriate, indelible.” But, ‘if no clear reference to the content of the information provided electronically is made on the label’, Brussels writes, ‘It could be considered as hidden mandatory information’. Consequently: ‘The presentation of a QR code should be clear to consumers for its content, i.e. the mandatory information presented electronically’.

From all this, the EU executive implies that “generic terms or symbols (such as the information ‘i’) are not sufficient to fulfil these obligations”. So, for the QR code: ‘It is necessary to use a header’ like the one already used for paper labels of other foods, ‘containing the word “ingredients”‘.

So the QR code with the ingredients is not enough, and ‘ingredients’ must be written. All those who have already labelled wine by putting only the QR code now find themselves being outlawed, just because the Commission waited until the last minute, when the wine labels were ready, to make the relevant communication. If you want digitalisation you have to take the good with the bad, but never mind: we are talking about the EU, not a normal organisation.

According to the Italian Wine Union (UIV), and the European Committee of Winegrowers (Comité Vins – CEEV), the guidelines are: ‘They nullify what was previously agreed’. The two organisations thus demand their urgent amendment because: ‘They put a European economy worth 147 billion dollars a year out of business’.

Who knows if this is not precisely the mission of the EU bureaucrats..

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