On August 29, 2023, Wine Australia hosted an informative online seminar to shed light on the impending changes to labelling requirements in the European Union (EU). While this webinar clarified several aspects of these upcoming changes, it also left many questions unanswered.
The imminent changes to labelling requirements in the European Union (EU) are set to reshape the wine industry in Australia and across the globe. These new regulations signal a broader shift towards greater transparency and consumer awareness in the food and beverage industry. Today’s consumers are making more informed choices about their products, particularly nutrition, allergies, and safety.
Whilst this conversation concerns wine producers exporting and selling in the EU, mandatory labelling requirements are hotly anticipated to extend to other markets globally and across all alcoholic products like beer and spirits. With just three months remaining until these changes take effect, Cellr believes that wine, beer and spirits brands and their exporters should be proactively preparing themselves for change.
First, let’s recap these new regulations and what we know.
For over two decades, food producers have been required to display ingredients and nutritional information to better inform consumers what they are purchasing. Up until now, alcoholic beverage producers (beer, spirits or wine) have managed to avoid listing both the ingredients and nutritional information on packaging and labels.
Starting from December 8, 2023, new regulations mandate that all wine sold in the European Union (EU) must include a nutrition declaration, energy values, and a list of ingredients. These new requirements add to the existing EU labelling standards, including allergen information, which must be adhered to.
However, implementing these changes on wine labels poses significant challenges. These include overcrowding labels, managing language translations for different EU member states, and updating labels in case of any changes to the product after printing. The new EU label legislation has introduced eLabels as an approved off-label solution for delivering ingredient and nutrition information to address these challenges. It’s worth noting that using off-label solutions comes with strict conditions, making it impractical for brands to host this information on their websites or connect it with third-party QR code generators.
Repercussions of Non-Compliance:
Non-compliance with these new EU regulations can have serious consequences. While some uncertainty remains, the EU has clarified that wine failing to comply with the new rules may be removed from the market. Additionally, financial penalties can be imposed per EU Regulation 1306/2013 Chapter IV, Article 89. Enforcement will be delegated to and handled by each EU member state.
Ultimately, from 8 December 2023, omitting or providing incorrect information will be considered consumer fraud, akin to mislabelling the varietal, region, or alcohol volume. Non-compliance in this space will not only affect a business or brand but will likely have large-scale negative repercussions on the whole alcohol industry.
Timeline and Ambiguity:
The regulations state that these requirements will only apply to wine “produced” on or after 8 December 2023; however, there’s a layer of ambiguity regarding the term ‘produced’. Australia’s leading industry body, Wine Australia, believes these regulations apply only to wines produced in the 2024 vintage and beyond. Yet, there’s ongoing uncertainty about the precise meaning of “produced” in the context of the winemaking process. Wine Australia has sought formal confirmation from the European Commission to clarify this definition.
Until this ambiguity is resolved, wineries are encouraged to prepare all their future labels to ensure they are future-proofed for the impending legal changes.
As the deadline for the latest EU wine label regulations approaches, Cellr has four proactive tips to help you prepare effectively:
1. Select A Delivery Method: Decide whether you’ll deliver mandatory information on or off the label. While off-label delivery is a practical choice, research both options carefully to make an informed decision. If you opt for on-label delivery, consult with your label designers and printers well in advance to understand the required changes and printing schedules. For those considering the dynamic nature of off-label eLabels, start implementing a solution now and ensure it complies with GDPR, data-tracking restrictions, and other legal conditions.
Cellr’s eLabel solution is designed with the wine industry in mind, ensuring easy compliance and allowing wine producers to focus on core business. Pricing starts at $400 AUD annually, making it an affordable option for wineries of all sizes.
Several global partners, including Avery Dennison and Affinity Labs, also trust the Cellr solution. With millions of products connected through Cellr, you can rely on our experience and expertise to navigate these changes seamlessly.
2. Prepare All Future EU Labels: If you choose the eLabel method, incorporate the nutritional information requirements into your subsequent label changes. This proactive approach ensures that your labels align with the upcoming changes seamlessly. Any criteria to change can happen at any time within the Cellr system. When changing your labels, always know any mandatory requirements for the label’s intended market.
3. Establish Strong Processes: Ensure you have a robust winery management software system to track all ingredients and additives and understand your requirements to analyse wine samples. Reliable process recording is critical for compliance and maintaining transparency. Cellr is also proudly building partnerships with complimentary service providers to ensure brands can deliver their compliance easily, accurately, and in a timely manner. One of these partnerships is with Affinity Labs, Australia’s leading advanced analytical and consulting firm for the food and beverage industry.
4. Stay Informed: Stay connected with your industry wine body for the latest updates and guidance on export regulations, including physical and digital label information. This proactive communication ensures that you’re well-prepared for any evolving requirements.
Contact Cellr for Your eLabel Solution.
As these EU wine label regulations’ deadlines loom, wine brands and exporters must act. The evolving landscape of labelling requirements demands proactive preparation, and Cellr is here to assist you in delivering an easy and effective eLabel solution to remain compliant. By understanding the regulations, choosing the correct delivery method, preparing labels in advance, tracking ingredients meticulously, and staying informed, you can ensure compliance, protect your business, and provide consumers with transparent and accurate product information. Don’t risk non-compliance; contact Cellr today to access our cost-effective, wine-centric eLabel solution.