From 8 December 2023 onwards, all wines sold in the EU that were not produced before this date will have to include ingredient, allergen, energy, and nutritional information in all EU languages.
South African wine exporters have been proactive in approaching this deadline of one of their most important export destinations. Assisted by wine industry bodies, producers have been familiarising themselves with the requirements and started taking the necessary steps to ensure compliance.
The cost of reflecting the truth
Applying nutritional labelling rules to wine is a win for consumers. Transparency about what is in the bottle other than fermented grapes could benefit wine drinkers as well as producers of wine with nothing to hide and, arguably, makers of natural wines with shorter lists of ingredients.
The new law prescribes that intolerance, allergy, and energy information must be on the physical label, while ingredient and nutrition lists can be provided via a QR code, linking to an independently hosted e-label. Lowered alcohol or de-alcoholised wines are also included in the same regulations as normal, alcoholic wines, with some additional requirements.
Stellenbosch-based Kleine Zalze already includes nutritional information and QR codes on most of their labels. Cellarmaster RJ Botha advises an early start. “It is important to do research and the necessary analyses as the process of label design changes can be costly and it takes time to get approval,” Botha says.
Peter Pentz Jr. of Groote Post Vineyards in Darling concedes that implementing the required changes has been more challenging than anticipated. “We still find ourselves in the midst of grappling with the complexities of this new legislation,” Pentz says. “The administrative burden and associated costs are significant concerns, especially for producers who already navigating a demanding industry.”
"An excellent resource": The DIGI-label platform
Pentz recommends the DIGI-label platform, developed specifically for the South African wine and spirit industry: “This is an excellent resource that allows you to generate QR codes with the required information, and the best part is that it comes with no subscription fees.”
The DIGI-label platform provides a wine product’s nutritional information, ingredients list, and related warnings to consumers electronically via a QR code. According to Wendy Jonker Hanekom, administering officer of the Liquor Products Act, translation into all EU languages will be enabled on the DIGI-label platform before the December 2023 deadline.
Furthermore, the platform offers producers access to an energy calculator, a tool developed by the Wine and Spirit Board, Winetech and Wines of South Africa (WoSA) in collaboration with the National Department of Agriculture based on international examples and analytical results of nutritional values shared by various role players. The energy calculator is also available on the Wine Online platform, where producers can utilise their existing routine analyses with no additional analyses needed.
Ask for approval
Hanekom regrets the uncertainty around the new requirements and the challenging situation that this creates for South African producers. “We had to interpret many of the requirements ourselves from the EU legislation or had to rely on other countries' comments and interpretations,” she explains. “The only feedback comes via the exporters' agents or importers in the EU, who talk directly to their own governments. This is currently the safest way for a producer to make sure that their labels do comply.”
Hanekom offers practical advice for exporters:
- To determine the energy values of wines, use the online calculator and practice with it to learn more about the impact of alcohol and sugar values, something that could help with future blends that remain relatively the same.
- To ensure compliance, especially with regards to language and translation requirements, first check, verify and sign off the labels with your agent and/or overseas client before the labels are printed.
- To prevent issues with wording and language, use a QR code that has no wording on it and only one QR code per label.
- To anticipate different interpretations of the requirements by different EU countries and to prevent costly reprints, don’t print too many labels at once.
Non-compliance may lead to fines and trade restrictions, but the enforcement of the new law is still unclear. Hanekom advises any exporters who experience problems with nutritional labelling in the EU after the December deadline to contact her at WendyJ@Dalrrd.gov.za to assist.
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