Vermouth and Sangria Labels: EU E-Label Rules

Vermouth, sangria, spritz-style wine drinks and wine-based cocktails are not wine in the legal sense, so it is easy to assume the EU e-label rules for wine pass them by. They do not. Since 8 December 2023, aromatised wine products sold in the EU have needed a nutrition declaration and a list of ingredients, under rules written into Regulation (EU) No 251/2014 by the same 2021 reform that changed wine labels. The rules also allow the same QR code shortcut that wineries use. This guide covers which products are caught, what has to stay on the bottle, what can move behind a code, and where the ingredients list for these drinks differs from plain wine.

Plain-language guidance, not legal advice. Check the current regulation text and your member state's guidance before you print.

What counts as an aromatised wine product?

Regulation 251/2014 sets out three categories. Each one is defined by how much wine it contains, its alcohol strength and how it is flavoured, so check the regulation for the exact thresholds before you decide which one your product belongs to.

Products made with spirits as the base are spirit drinks, which follow different labelling rules, and plain still or sparkling wine follows the wine rules in the CMO Regulation. If a product sits near the line, confirm its category first, because that decides which rulebook applies.

What the rules require

Article 6a of Regulation 251/2014 says the labelling of aromatised wine products marketed in the EU must include a nutrition declaration and a list of ingredients, both as defined in the general food information rules (Regulation (EU) No 1169/2011). Products produced before 8 December 2023 may still be sold until stocks run out, but anything bottled since then needs both.

The two particulars can be split between the label and an electronic page, in almost exactly the way wine can:

• The nutrition declaration on the bottle can be limited to the energy value, which may be shown with the symbol "E". The full declaration then goes on an electronic page.
• The list of ingredients can go entirely on an electronic page.
• Allergens cannot. Substances such as sulphites, egg or milk products must appear on the physical label, as the word "contains" followed by the substance name.
• The electronic page must be identified on the package or label, must not be shown alongside sales or marketing information, and must not collect or track user data.

Those last conditions are where many first attempts go wrong. A QR code that lands on the brand's homepage, a cocktail recipe page with a shop button, or a page that loads an analytics script does not meet the rule. The e-label page has to be neutral.

Ingredients: where vermouth differs from wine

Aromatised wine products start from wine and then add other things: sugar, caramel, herbs and botanicals, fruit juice, alcohol and flavourings. Commission Delegated Regulation (EU) 2024/585 sets specific rules for how those ingredients are named. In short, the grapevine products used in an aromatised wine can be listed as "wine" or by the names of the specific products used, so check the delegated regulation for the details of how your own recipe has to be written.

The delegated regulation also covers packaging gases, which can be shown with the phrase "Bottled in a protective atmosphere", and the order and naming of grape products used. Because the rules are specific, write the list from the regulation text rather than copying a plain-wine template. Our guide to writing a wine ingredients list explains the wine side, including additive categories and E numbers, which you can then wrap inside the "wine (...)" entry.

Nutrition: sugar changes the numbers

Vermouth and sangria often carry much more sugar than dry wine, so the energy value and the sugar line move a long way from a typical table wine. The full declaration, per 100 ml, covers energy, fat, saturates, carbohydrate, sugars, protein and salt, and the energy value has to appear on the label itself. Work from lab results or a careful recipe calculation for each product, not from a generic figure. Our guide to calculating wine calories shows how alcohol, sugar and other components add up to the energy value.

What should be on the bottle

• The energy value, which may be shown with "E".
• Any allergens, written as "contains" plus the substance.
• A QR code or other electronic means pointing to the full nutrition declaration and ingredients list, clearly identified as that information rather than left as an unlabelled code.
• The other mandatory particulars for aromatised wine products, such as the sales denomination, alcohol strength and net volume, which are outside the scope of this guide.

How the code must be identified has caught out wineries too. The European Commission's Q&A on wine labelling discusses whether a symbol such as an "i" on its own is enough. That Q&A was written for wine, so treat it as a strong indication and confirm with your national authority for aromatised wine products. A plain word next to the code is the safest choice.

Two codes on one bottle

Aperitif brands usually want a code that tells the story too: serves, spritz recipes, where to buy. That page cannot be the e-label page, because the e-label must stay free of marketing and tracking. The common answer is two codes, each with its own label, such as "Ingredients and nutrition" for the legal page and "Recipes" or "Reorder" for the brand page. Our guide to two QR codes on one label covers placement and wording, and our print specs guide covers size, quiet zone and contrast.

A checklist before you print

• Confirm the product's category under Regulation 251/2014.
• Write the ingredients list using the delegated rules, with the wine base shown as "wine" followed by its own ingredients in brackets.
• Calculate the full nutrition declaration per 100 ml, and print the energy value on the label.
• Put allergens on the label with "contains".
• Point the e-label code at a neutral page with no marketing, shop links or tracking.
• Label the e-label code clearly, and give any marketing code its own label.
• Scan the press proof on the real bottle before the run.
• Keep a record of each code's destination per product and batch, so reprints use the same links.

FAQs

Does vermouth need an EU e-label?

Vermouth needs a nutrition declaration and ingredients list if it was produced from 8 December 2023 and is sold in the EU. An e-label is optional: you can print everything on the bottle, or keep the energy value and allergens on the label and move the rest behind a code.

Is sangria covered by the wine e-label rules?

Sangria is an aromatised wine-based drink, so it follows Regulation 251/2014 rather than the wine rules, but since the 2021 reform those rules require the same nutrition and ingredients information and allow the same electronic option.

Can the e-label page show cocktail recipes?

No. The ingredients and nutrition page must not be shown with information intended for sales or marketing. Put recipes, stories and shop links on a separate page behind a separate code.

Can I use analytics on the e-label page?

No. The rule says no user data may be collected or tracked on the electronic page. Keep scan tracking on the marketing code only.

Do I need a new e-label when the recipe changes?

If the ingredients or nutrition values change, the page has to match the bottles it serves. Give the new batch its own page rather than overwriting one that older bottles still point to. Our guide to new vintages explains the same problem for wine.

Where does Tapline fit?

Tapline is not your compliance check or your recipe record. It powers the second code on the bottle: a story page for each product, a reorder button that sends buyers to your shop or stockist list, and scan counts per code, all editable after the labels are printed, so the printed code can stay the same across batches. On the Scale plan the page can be shown in several languages for export markets. The marketing page is never the legal e-label. Tapline can also host a separate, neutral e-label page for wine that you fill in yourself, and you are responsible for its accuracy. Tapline is built by Esipick, which has been building software for brands since 2013.

Related: what happens after the scan.

Related: EU e-label rules for wine.

Related: how to write a wine ingredients list.

Related: how to calculate wine calories for an e-label.

Related: wine allergen labelling.

Related: two QR codes on one label.

Related: wine label QR code size and print specs.

Related: QR codes on spirits labels.

Related: wine e-labels and new vintages.

Related: pricing.