Still not on the Label

What do the EU's new labelling regulations mean for natural wine?

Who remembers Friday December 8th, 2023? It wasn’t that eventful, apart from Hunter Biden being charged for tax evasion. But it was the day that EU regulation 2021/2117 entered into force. A date that might come back to haunt winemakers in the future.

Included in the regulation are revised rules for wine labelling that require wineries to declare ingredients, nutritional and recycling information, either directly on the label or via a QR code. It’s been a long time coming. Wine is one of very few food products on the market that has escaped mandatory ingredient labelling, along with beer and spirits. It has no doubt helped maintain the fiction that all wine is just made from grapes.

Now it is finally law for wine either produced in or imported to any country within the European Union. What does this mean for the consumer or the winemaker, and will it help make the differences between natural or low intervention wine and mass-produced commodity wine any clearer?

The answer to the second question is a definite no. Plenty of natural wine commentators rubbed their hands with glee at the idea that suddenly ‘big wine’ would have to disclose long lists of nasties that were added to your €5 Chardonnay or ‘two buck chuck’. Raisin, the creators of the Natural Wine App, optimistically published this in February 2024:

…for the more chemically inclined winemakers, they will need to provide a list of acidity regulators, preservatives and antioxidants, sequestrates, fermentation activators, clarifying agents, stabilising agents, enzymes, gases and packaging gases, fermentation agents, defect correctors, and more. Wow!

Miquel Hudin, writing in Decanter magazine in July 2023, states (my italics):

Any wine sold in the EU which was produced and/or labelled from that date will be legally required to declare any ingredient added during the winemaking process (e.g. sulphur dioxide, commercial yeasts, additional sugar, acidity, colourants etc.), and which is contained in the finished wine.

Neither is 100% correct. The EU’s own questions and answers document on the implementation of the new regulations makes it clear that ‘processing aids’ which do not contain an allergen and which are not deemed to be present in the final wine do not have to be declared on the ingredients list.

Significantly, this means that a winery inoculating with lab yeast (AKA Hudin’s “commercial yeast”) will not need to declare it, because it is considered to be fermented out and thus not present in the finished wine. Much of Raisin’s list also escapes the labelling burden. Fermentation activators, clarifying agents, enzymes and fermentation agents all fall under the “processing aids” banner and do not have to be declared unless they contain an allergen.

Thus, wineries who fine (clarify) wine with egg whites (albumen) will need to list it as an ingredient. But fining with bentonite, by far and away the most common choice, does not need to be declared. Neither does isinglass, a gelatin fining agent extracted from fish bladders. Its use would certainly upset vegans but it is not covered by the EU’s list of allergens and it is deemed not to be present in the finished wine.

In short, you will still not be able to tell from the label whether a wine was spontaneously fermented or inoculated, whether it was filtered or clarified or whether other ‘processing aids’ were used to assist fermentation or malolactic - at least not unless the winery voluntarily provides additional information not required by law.

Conversely, wineries will now have to declare when they chaptalise (aka enrichment, the addition of fermentable sugars in the form of sugar itself or more commonly rectified concentrated grape must) or when they make corrections for acidity, by for example adding tartaric acid when there is a deficiency of acidity in the grapes themselves. There may well be surprises in store - word has it that many top Burgundy producers still routinely chaptalise.

The rules on sulphites remain unchanged, with any amount over 10mg/L requiring the wording “contains sulphites” both on the label and on any associated QR code or e-label.

Who Looks at QR Codes?

The new regulation introduces further complications. The ingredients list, plus the also newly required nutritional analysis and details about recycling, do not have to appear on the label itself. Recognising that there is very limited space on most wine labels, the regulation allows wineries to add a QR code to the back label, which will take the consumer to a web page containing the detailed information. It is likely that virtually all wineries will opt for this option, which effectively hides away all that extra detail in a place where almost no -one will ever bother looking. It’s probably the biggest dilution there is in the new regulations.

You might think that wineries can just provide the required detail on their website, and have the QR code link there. Not so fast. The EU says that:

The information on the full nutritional declaration and list of ingredients shall not be displayed with other information intended for sales or marketing purposes, and that no user data shall be collected or tracked… the presentation of this compulsory information as part of the producers’ website does not seem to comply with the conditions set out in Article 119(5), as the website of a wine producer is typically expected to contain commercial information relevant for marketing and/or sales.

In other words, wineries that decide not to clutter their labels with the considerable volume of additional information must now find a ‘neutral’ online service to host their QR codes and e-labels. Such services already exist, typically to allow wineries to easily manage, update and publish technical sheets each year. Vinofact is one example, based in Austria and used by an impressive list of top Austrian wineries such as Fritsch. Note that the datasheets in this example would not be compliant with the new regulations, because they contain biographical information about the winery. One assumes that Vinofact has a bare bones version of their tech sheets for that purpose.

Here is a fully compliant example, from the winery Chateau Shuette in Bordeaux:

I asked Wagram-based biodynamic grower Martin Diwald, a client of Vinofact, about the cost. He said it was very reasonable, not amounting to more than around €500 a year for his entire product line. He intends to use Vinofact to fulfill his obligations under the new regulations.

Emma Bentley who runs operations for Vinnatur, an association of around 200 natural winemakers from all over Europe, presented a slightly different picture. “We’ve received quite a few requests from companies asking us to forward their offer to our members” she said, adding “we're getting a ton of people selling this service for a lot of money - I’ve seen one asking for €100 per label [wine] per year.” Perhaps these do not sound like large sums, but for ultra-boutique wineries making 20,000 bottles of wine a year or less, additional lab analyses and QR code hosting could easily add €0.50 or more to the wholesale cost of every bottle. This in turn translates into two or three times that amount on the final retail price. The EU regulation requires the QR code and e-label for each specific wine and vintage to be kept online for ten years, so wineries could see costs multiply exponentially over the scheme’s first decade.

Free as in Beer

Bentley has instead started recommending a free solution to Vinnatur’s members. UK based startup Little Wine offers QR code and e-label hosting to any winery for no cost. Their business model is based around a premium mobile app¹ targeted at sommeliers and importers who require detailed technical data on the wines they are selling. Offering the service to wineries for free allows Little Wine to collect the same data that they require for their app, so it appears to be win-win for all concerned.

Christina Rasmussen, one half of the team behind Little Wine, explained that “Franz Weninger told us about this new law in May 2023. And it turned out it was really easy for us to add this functionality, it’s just another view on top of what we were already building.” Little Wine is not the only free option for e-labels. Raisin offers a similar service, however unlike Little Wine, their offering is only available for winemakers who comply with their natural wine definition. Furthermore, Raisin claims it has a virtual queue of around 3,000 wineries awaiting validation. In order to jump the line, wineries must elect for their paid option at €249 per year.

Reaction to the new regulations

Despite offering the service to winemakers, Rasmussen is ambivalent as to whether the new EU regulation really benefits the consumer. She says “if absolutely everything that a winemaker could do, including farming inputs and all winemaking inputs were declared, that would help people to fully understand how wine is made”, but notes that “the processing aid thing is really confusing - yeast has to be listed for bread, so why not for wine?”

Her views were echoed by almost everyone I spoke to for this article. Martin Diwald was blunt, stating simply that the new labelling scheme “doesn't have any value for the consumer at all [due to its lack of completeness]”. Emma Bentley, speaking on behalf of Vin Natur said “we advocate transparency for the consumer, so the idea of having an ingredients list is something that we are totally for. But recycling and nutritional information is a bit silly. Who actually cares how much protein or fat there is in a wine?” She does however feel that the wine industry has had it too easy for too long, adding “Beer brewers have so many more restrictions on them before they can even start selling. Winemakers don't know how good they've had it.”

Istria-based consultant winemaker Milan Budinski, who makes wine under his own label OMO, went further, telling me that “the biggest problems and scams in the wine business, false labelling, false provenance, false organic, overuse of pesticides etc will not be solved even a bit.” He also expressed concerns that “winemakers [will] feel ashamed by saying that they might be using very safe additives, such as tartaric, malic, mannoproteins and so on, and being aware that the first ones to report it on the label will be crucified.”

There is very varied awareness of the new regulations among winemakers. Some growers I queried had only the vaguest idea of what they needed to do or what the regulations entail. In theory, all wine produced from the 2024 vintage on will need to comply, however the EU has already offered a two year grace period where it will not be too punitive on wineries who fail in their obligations.

One natural winemaker who has long taken transparent wine labelling to its logical extreme is Fabio Bartolomei, who makes wine just south of Madrid under the label Vinos Ambiz. Here is an example of his back labels, which cover the entire body of the bottle. It’s still not enough to comply with EU regulation 2021/2117 though!

This article was amended on July 17th, to clarify that Little Wine does not sell winery’s data.

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Little Wine has published a useful and accurate summary of the new wine labelling regulations here.

The following EU documents contain much of the detail on the revised labelling regulations:

https://eur-lex.europa.eu/eli/reg_del/2019/934/oj

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02019R0033-20231208

1. Little Wine’s app is pre-launch at the time of writing, but interested wine professionals can sign up to a waiting list on their site.