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Wine and Allergens

Bearing in mind the long shelf-life of wines (beverages containing 10% or more by volume of alcohol are exempt from the requirement to indicate a date of minimum durability), previous legislation which granted certain derogations in relation to allergen information must be taken into account when reading the information provided on wine bottles.

Wines labelled before 25 November 2005

The requirement to indicate allergens was first introduced in 2005 (Directive 2003/89/EC). Therefore, any wines (as defined in Annex VII, Part II of Regulation (EU) No. 1308/2013) placed on the market or labelled before the 25 November 2005, are exempt from the obligation to indicate the use of any of the EU listed allergens.

Wines labelled from 25 November 2005 to 29 June 2012

In 2005, Commission Directive 2005/26/EC established a list of food ingredients or substances which were provisionally excluded from the 25 November 2005 from the requirement to indicate their use as an ingredient in wines. Therefore, wines which were placed on the market or labelled from the 25 November 2005 until the 30 June 2012 are not required to indicate the following:

  • Lysozyme (produced from egg) used in wine
  • Albumin (produced from egg) used as fining agent in wine
  • Milk (casein) products used as fining agents in wines

Directive 2005/26/EC was repealed by Commission Directive 2007/68/EC. However, an amendment (Commission Regulation (EU) No. 1266/2010) permitted wines as defined in Annex VII, Part II of Regulation (EU) No 1308/2013, which were placed on the market or labelled before 30 June 2012, and which comply with the provisions of Directive 2005/26/EC, to be marketed until stocks are exhausted.

Therefore, wines which were placed on the market or labelled prior to 30 June 2012 are not required to indicate lysozyme, albumin or milk as detailed above.

Wines labelled after the 30 June 2012

Commission Implementing Regulation (EU) No 579/2012 sets out requirements regarding allergen information for wines which is applicable to wines made completely or partially from grapes harvested in 2012 or later and labelled after the 30 June 2012.

This Regulation set out requirements for wines as regards the terms concerning milk and milk-based products and eggs and egg-based products as referred to in Annex II to Regulation (EU) No 1169/2011. An indication of the presence of egg-based or milk-based products ingredients is only mandatory for wines if their presence can be detected in the final product using the analysis methods referred to in Articles 80(5) and 91(c) of Regulation (EU) No 1308/2013.

Regulation (EU) No 579/2012 states that for the purposes of indicating sulphites/sulfites, milk and milk-based products and eggs and egg-based products the terms that must be used are those listed in part A of Annex X to Regulation (EU) No 579/2012.

The allergen indications in English may be in one of the following forms:

  • In the case of sulphur dioxide: ‘sulphites’, ‘sulfites’, ‘sulphur dioxide’ or ‘sulfur dioxide’
  • In the case of egg : ‘egg’, ‘egg protein’, ‘egg product’, ‘egg lysozyme’ or ‘egg albumin’
  • In the case of milk: ‘milk’, ‘milk products’, ‘milk casein’ or ‘milk protein’

These terms may be accompanied, as applicable, by one of the pictograms shown in part B of Annex X to Regulation (EU) No 579/2012.

In Summary

Wines placed on the market or labelled before 25 November 2005, are exempt from the obligation to indicate the use of any of the EU listed allergens.

Wines placed on the market or labelled between the 25 November 2005 and 30 June 2012 must indicate the presence of the EU listed allergens but are exempt during that period from indicating the use of lysozyme (produced from egg) used in wine; albumin (produced from egg) used as a fining agent in wine; or, milk (casein) products used as a fining agent in wine.

Wines made completely or partially from grapes harvested in 2012 or later and labelled after 30 June 2012 must comply with the allergen requirements set out in Regulation (EU) No 1169/2011 and Regulation (EC) No 607/2009 as amended by Regulation (EU) No 579/2012. However, note that Regulation (EU) No 579/2012 states that in the case of egg/egg products or milk/milk products ingredients the indication is only mandatory if their presence can be detected in the final product using the analysis methods referred to in Articles 80(5) and 91(c) of Regulation (EU) No 1308/2013.
 


Last reviewed: 17/1/2018

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