Wine Allergen Labelling: Sulphites, Egg and Milk

Allergens are the one part of the new EU wine label rules that a QR code cannot take off the bottle. Since December 2023, wine made for the EU market can move its full ingredients list and nutrition table to an e-label, but sulphites, egg and milk still have to be declared on the physical label. Getting this wrong is one of the quickest ways to end up re-stickering a pallet. This guide covers when each allergen must be declared, the exact words allowed, where they go on the label, and how they fit with the two-QR back label.

Plain-language guidance, not legal advice. Check the current regulations and your importer's requirements before you print.

Which allergens apply to wine?

EU food law lists 14 allergens, but in practice three come up in wine. Sulphites, because sulphur dioxide is used as a preservative in almost every wine. Egg, because egg white (albumin) and egg lysozyme are used for fining and stabilising. Milk, because casein and other milk proteins are also used as fining agents. Delegated Regulation (EU) 2019/33 sets the specific terms wine labels must use for these three.

When do you have to declare them?

The sulphite threshold catches nearly all wines, including most labelled as low-sulphite or natural, because yeast produces some sulphur dioxide during fermentation even when none is added. For egg and milk, the test is the residue in the finished wine, measured by an approved method, not whether the agent was used. A wine fined with egg white and filtered so that nothing is detectable does not need the declaration, but you should keep the lab result on file. Isinglass, a fish-derived fining agent, does not need an allergen declaration when it is used to fine wine in the EU.

Where allergens go when the ingredients list is on the label

If you print the full ingredients list on the bottle, the allergens appear inside that list under their allowed names, and they must stand out from the other ingredients, usually in bold, capitals or a different background colour. In this case a separate "contains" line is not needed. The Commission's Q&A on wine labelling covers how allergen information may be repeated, including the optional pictogram, so read its wording before you print.

Where allergens go when the ingredients list is on an e-label

This is the setup most wineries now use, and it is where mistakes happen. If the ingredients list is on a page reached by QR code, the physical label must still carry the allergens, written as the word "contains" followed by the allowed term, for example "Contains sulphites" or "Contains sulphites, egg". The e-label's ingredients list must also show the same allergens, emphasised in the same way as on a printed list. So the allergen appears twice: once on the bottle and once on the e-label page.

The "contains" statement does not have to sit in the same field of vision as the other mandatory particulars such as the name, alcohol strength and volume, so it can go on the back label beside the QR codes. The energy value, shown with the "E" symbol, must also stay on the physical label even when the full nutrition table moves online. Our guide to calculating wine calories for an e-label covers that number.

Languages: the bottle needs the right words for each market

The allergen terms must be in a language the consumers of the country where the wine is sold can easily understand. That means "Contains sulphites" works for the UK and Ireland, but a wine sold in Germany needs "Enthält Sulfite" and in France "Contient des sulfites". Annex I of Regulation 2019/33 lists the allowed term in every EU language. Wineries exporting to several countries often print the statement in two or three languages, or rely on the optional pictograms alongside one language. Check each market before you print, because this is text on the bottle and cannot be fixed by editing a web page.

Pictograms: optional, never a replacement

The EU has standard pictograms for sulphites, egg and milk. You may print them in addition to the words, and many exporters do because they help shoppers who don't read the label language. They do not replace the text declaration, and if you use them they must follow the official designs. Don't draw your own icons.

What about the UK and US?

In the UK, wine must state "contains" followed by the allergen when sulphur dioxide is above 10 mg per litre, or when egg or milk fining residues are detectable above 0.25 mg per litre, according to the government's wine labelling guidance. The UK does not currently require a full ingredients list for wine. In the US, the TTB requires "Contains Sulfites" when sulphur dioxide is 10 parts per million or more; declaring egg or milk fining agents is voluntary there, with its own TTB rules. Our export guide covers EU, UK and US label rules side by side.

A back-label checklist for allergens

• Get the total sulphur dioxide figure from your lab for each wine and vintage.
• Record every fining agent and stabiliser used, and test for egg and milk residues if any were used.
• Decide whether the ingredients list goes on the label or on an e-label.
• Label list: emphasise allergens inside the list; a separate "contains" line is not needed.
• E-label: print "Contains" plus the allowed term on the bottle and emphasise the same allergens on the e-label page.
• Use the allowed term in the language of every market the wine is sold in.
• Add the official pictograms if you want them, never instead of the words.
• Keep the energy value (E) on the physical label.
• Scan a printed proof of the e-label code and check the page shows the allergens correctly.

Common mistakes

The most common mistake is moving everything to the QR code, allergens included, to free up space on a small back label. The second is a "contains sulphites" line in English only on a wine shipped to several EU countries. The third is copying last vintage's label when the fining agents changed, so egg is declared when it wasn't used, or missing when it was. Each of these is printed on the bottle, so the only fix is a new label or a sticker.

FAQs

Can allergens go only on the e-label?

No. If the ingredients list is on an e-label, the allergens must still be printed on the physical label after the word "contains". They also appear in the e-label's ingredients list.

Do I need "contains sulphites" if the ingredients list is printed on the label?

Not as a separate line. Sulphites appear inside the printed list, emphasised. Check the Commission's Q&A on wine labelling for how it treats any repetition, including the optional pictogram.

Does organic or natural wine need a sulphite declaration?

If total sulphur dioxide is above 10 mg per litre, yes. Fermentation produces some on its own, so check the lab figure rather than assuming.

We fined with egg white. Do we have to declare egg?

Only if a residue of 0.25 mg per litre or more remains in the finished wine. Test it, and keep the result with your batch records.

Where does Tapline fit?

Tapline is not your allergen statement. It powers the second code on the back label: a story page for each wine with tasting notes, a reorder button to your shop or stockist list, and scan counts per code, all editable after the labels are printed. 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 that you fill in yourself, and you are responsible for its accuracy. Keep your allergen words on the bottle. Tapline is built by Esipick, which has been building software for brands since 2013.

Related: what happens after the scan.

Related: how to write a wine ingredients list for an EU e-label.

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

Related: two QR codes on one label.

Related: wine QR codes for export: EU, UK and US.

Related: EU e-label rules for wine.

Related: pricing.