New EU Wine Labelling Guidelines Threaten to Upend Industry and Waste Resources

In a controversial turn of events, the European Commission's recent guidelines on wine labelling have sparked significant unrest within the wine industry. Released mere weeks before the enforcement of new labelling rules, these guidelines have introduced unexpected changes that could lead to the wastage of hundreds of millions of wine labels, already printed and stocked by producers.

This situation stems from the European Commission's reinterpretation of Regulation (EU) 2021/2117, set to be effective from December 8, 2023. This regulation mandates the inclusion of ingredients and nutrition information on labels of wines and aromatized wine products. While it offers the option of providing this information electronically, the new guidelines have shifted the understanding of these provisions significantly.

The European Committee of Wine Companies (Comité Vins – CEEV) has expressed its urgent call for a modification of these guidelines. Mauricio González Gordon, President of CEEV, highlighted the extensive preparations undertaken by the industry to comply with the original interpretation of the regulation. He noted the investment in modifying label designs and the printing of several hundred million labels, many of which are already in the marketplace.

The core of the issue lies in the Commission's new stance on the presentation of QR codes, which, according to the new guidelines, must be clearly identified with the term "ingredients." This unexpected specification, along with ambiguities regarding language requirements, has created significant challenges for wine producers. The CEEV argues that this late-stage reinterpretation undermines the principles of legal certainty and legitimate expectation for economic operators.

The impact of these changes is not limited to logistical challenges. It also signifies a potential setback in the principles of proportionality governing the free movement of goods, competitiveness, and consumer information.

Ignacio Sánchez Recarte, Secretary General of CEEV, criticized the Commission's interpretation as being overly bureaucratic and not in line with the spirit of the Regulation. He emphasized the negative impact on the Single Market for wines and the disproportionate interpretation of the Common Market Organisation (CMO) and Food Information to Consumers Regulations. He also expressed concerns about the diminished advantages of the electronic labelling system under these new guidelines.

In response to these developments, several Member States, including Spain, Italy, France, and Portugal, along with the European Parliament's Committee on Agriculture and Rural Development, have expressed support for the CEEV's interpretation and conveyed their concerns to the European Commission.

The wine industry now finds itself in a precarious position, facing substantial financial and operational losses due to the late introduction of these new labelling requirements. The CEEV is actively exploring all possible options to safeguard the interests of wine companies and ensure the provision of appropriate information to consumers, while maintaining the integrity of the Single Market.