The new EU wine labelling rules: revolution or substantial continuity? by Giuliano Lemme

The new EU wine labelling rules: revolution or substantial continuity? Giuliano Lemme1 1. The previous regulatory framework; 2. Attempts to increase clarity of information: associations, certification - 3. The new Regulation: the problem of nutritional information - 4. Wine ingredients: an oxymoron? - 5. Reflections on market segmentation: wine increasingly an elite product? 1. The previous regulatory framework The subject of wine labelling, with its substantial differentiation from the rules in force for foodstuffs, has long been the subject of lively debate. I addressed this topic in an essay in 20212 . In particular, my previously expressed position3 was in the sense of a substantial informational insufficiency of European legislation, especially with regard to the indication of wine components. Indeed, I concluded, 'It is clear from the framework of legislation on wine labelling that not all significant details of single wines may be inferred from their label. It is also clear that individual producers may be able to inform consumers of the specific characteristics of their wines; however, such characteristics may or may not be useful to consumers'. In other words, the European legislation (in particular, Reg. 1169/2011) provided, in my opinion, a framework that was in some respects incoherent, as it omitted the obligation to indicate the ingredients of wine, thus creating an 1Full Professor of Economics Law, University of Modena and Reggio Emilia. 2G. LEMME, Wine labelling, in C.TORRES, F.J. MELGOSAARCOS, L. JÉGUZO (ed.), Wine Law, Estoril-Salamanca-Paris, 2021, pp. 171 ff. 3G. LEMME, Lo strabismo di Bacco. L'etichettatura dei prodotti vitivinicoli tra tutela del consumatore e reticenze legislative, in Riv. Quad. Dir. Ambiente, 2015, pp. 132 ff.

inevitable fragmentation, with added confusion coming from both the specific regulations of member states, the discipline of geographical indications, the regional classifications, and, finally, the rules of self-discipline of the various associations of producers and external certification bodies. In fact, we must not forget that the main purpose of the European Union's action with regard to consumer protection is to provide information that consumers are able to use to make informed choices4 . In turn, this line of action stems from studies on consumer behavior and a soft law approach to remedy their natural cognitive errors5 . It is therefore essential, for this approach to be truly effective, that the information be correct, complete but also easily understood by the average consumer, thus avoiding the risks of both misleading information and so-called information overload, which makes it more difficult for the consumer to distinguish information that is useful for his or her economic choices from information that is essentially irrelevant6 . In this respect, the quantitative, rather than qualitative, approach chosen by the European legislator, despite its laudable intentions, has been only partially successful. While it is certainly understandable that one wants to give due weight to completeness of information, it is also true that, in the presence of a large amount of information, companies tend to emphasize attractive visual elements on product labels, which tend to attract the consumer's attention by distracting him from the purely informative elements that are more relevant to 4Article 169 of the Treaty on the Functioning of the European Union states that 'in order to promote the interests of consumers and to ensure a high level of consumer protection, the Union shall contribute to protecting the health, safety and economic interests of consumers, as well as to promoting their right to information, education and to organise themselves in order to safeguard their interests'. 5D. KAHNEMANN, A. TVERSKY, Prospect Theory: An Analysis of Decision under Risk, in Econometrica, 1979; R. H. THALER, The Winner's Curse. Paradoxes and Anomalies of Economic Life, Princeton University Press, 1992 and Misbehaving. The Making of Behavioral Economics, New York, 2005; R. H. THALER & C. R. SUNSTEIN, Nudge. Improving Decisions about Health, Wealth and Happiness, New York, 2008; C. R. SUNSTEIN, Why nudge?, New Haven - London, 2014 6 N. K. MALHOTRA, Reflections on the Information Overload Paradigming Consumer Decision Making, in Journal of Consumer Research, 1984; N. K. MALHOTRA, A. K. JAIN, & S. W. LAGAKOS, The Information Overload Controversy: An Alternative Viewpoint, in Journal of Marketing, 1982; J. JACOBY, Perspectives on Information Overload, in Journal of Consumer Research, 1984.

him7 . The result is therefore, paradoxically, that every new regulation that increases information data is accompanied by a loss of value of objective data (information) as opposed to communicative data (marketing). Are there alternatives to this approach, which is often blatantly showing its limits? Yes and no. Certainly, clarity of information cannot be underestimated, because the perspective to be considered must be that of the average consumer, and not the expert consumer. So, to give an example - which I will necessarily take up again below - listing the list of additives in a food product is correct in terms of information, but not in terms of clarity, because the average consumer is unlikely to know the function and health effects of additives. On the other hand, would it be reasonable to change the legislation to require 'explanatory' labels? In perspective, this is possible, using technologies (typically, the QR codes) that allow the consumer to view a range of information not printed on the label. However, the natural 'laziness' that consumers display in their purchasing behavior, which induces them to put as little time as possible between their desire and its realization, hinders the effectiveness of this approach8 . In other words: are we sure that, before buying a packet of crisps at the supermarket, the consumer will hesitate in order to read the 'reasoned' list of additives, available on the web via the QR link? Faced with these dilemmas, as already clarified in a previous essay I wrote9 the European legislator on the one hand opted for the quantitative approach as far as foodstuffs are concerned, and on the other hand, in the case of wine10 , paradoxically chose a much more minimalist path, the effect of which is certainly to avoid information overload, but which at the same time ends up being scarcely informative, except for the most experienced consumers. For 7 T. L. CHILDERS & M. J. HOUSTON, Conditions for a Picture-Superiority Effect on Consumer Memory, in Journal of Consumer Research, 1984, emphasize the prevalence of visual elements over textual ones in the attention of the average consumer. 8 G.LEMME, La transizione giuridica. La crisi del diritto di fronte alla sfida tecnologica, Turin, 2023, p. 96 9 G. LEMME, Wine labelling, in C.TORRES, F.J. MELGOSAARCOS, L. JÉGUZO (ed.), Wine Law, Estoril-Salamanca-Paris, 2021, pp. 171 ff 10 Wine labelling legislation was the subject of Reg. 33/2019, which has to be coordinated with Reg. 1308/2013 and Reg. 1169/2011

others, the only essential element ends up being the packaging or, more precisely, the shape, colors and claims contained in the label11 . With regard to the latter, their inclusion on the label is permitted under the combined provisions of Articles 118 Reg. 1308/2013, 49 Reg. 607/2009 and 2 Dir. 13/2000. As a matter of fact, these claims tend to have every possible variation between the totally generic, not to say banal (especially when it comes to organoleptic descriptions or suggested pairings) and certainly more interesting and informative profiles, such as vinification methods and practices followed in the vineyard. Here again, the information is perceived very differently depending on the consumer's level of knowledge: experts tend to overlook the first type altogether, non-experts do not understand the scope of the second12 . In conclusion, prior to the enactment of the new rules, which we will deal with later, the regulatory framework for wine labelling showed wide margins of inconsistency, at least when compared to that for food labelling. I had pointed out this legislative 'strabismus', calling for a rethink of the rules, at least in an attempt to educate the consumer to make a more informed purchase. 2. Attempts to increase information clarity: associations, certifications Wine is undoubtedly one of the food products in which the market segmentation13 and, consequently, the final price, is most varied. This entails, as already partly mentioned above, the subdivision of consumers into multiple 11 L. DE MELLO, R. PIRES, Message on the bottle. Colors and shapes of wine lables, in AAWE Working Paper no. 42, 2009; E. LICK et al.Sensory expectations generated by colours of red wine labels, in Journal of Retailing and Consumer Services, 2017, 37: 146-158; F. CELHAY, H. REMAUD, What does your wine label mean to consumers? A semiotic investigation of Bordeaux wine visual codes, in Food Quality and Preference, 2018, 65: 129-145; D. A. JAUD, V. MELNYK, The effect of text-only versus text-and-image wine labels on liking, taste and purchase intentions. The mediating role of affective fluency, in Journal of Retailing and Consumer Services, 2020, 53: 101964. 12 On the different perception of label content depending on the consumer's experience see e.g. T. DRUGOVA, K. R. CURTIS, S. B. AKHUNDJANOV, Are multiple labels on food products beneficial or simply ignored?, in Canadian Journal of Agricultural Economics/Revue canadienne d'agroeconomie, 2020, 68.4: 411-427. 13 E. POMARICI et al. One size does (obviously not) fit all: Using product attributes for wine market segmentation, in Wine Economics and policy, 2017, 6.2: 98-106.

categories, whether one takes product knowledge, spending capacity or a combination of the two. And so, to give an example, someone who buys a bottle of Romanée Conti may do so either because he is a great connoisseur of Burgundy wines, or alternatively because the exorbitant price range makes it attractive as a status symbol. Now, if certainly for the latter type of consumers price is the main parameter guiding their choice, for the former it is conversely the information profile that is relevant. Connoisseurs are mainly interested in knowing, for example, the pedoclimatic characteristics, the working methods in the vineyard, the oenological practices, the ageing times. There is therefore an obvious aspiration on the part of producers, especially of quality wines, to attract this segment of consumers (who generally, due to socio-cultural characteristics, also have a medium to high spending capacity) by providing them with the required information. Hence the need to form associations between producers with similar production philosophies, and to issue external certifications attesting to the product's characteristics. As for the former, these are generally part of the 'activism' of producers14 , who generally identify themselves with the 'alternative' wine movements, e.g. biodynamic or natural. It has been demonstrated, in fact15 , the positive role of the producer's reputation and membership of 'ecological' movements in market penetration, in one with the changed social consciousness of individuals, who are increasingly inclined to value the sustainability of what they consume16 . Producer associations generally have a statute, or at least a set of rules, which members are required to apply: for example, on SO2 content, on the need for fermentation with indigenous yeasts, on types of treatment in the vineyard. 14 M. F. GARCIA-PARPET, French biodynamic viticulture: militancy or market niche?. London, Bloomsbury, 2014. 15 P. FANASCH, Survival of the fittest: The impact of eco-certification and reputation on firm performance, in Business Strategy and the Environment, 2019, 28.4: 611-628. 16 M. PINK, The sustainable wine market in Europe-introduction to a market trend and its issues, in Acta Scientiarum Polonorum. Oeconomia, 2015, 14.2.

From this point of view, a producer being a member of an association gives the consumer (of course, the expert consumer) immediate information on certain expected characteristics of the wine, without the need for these characteristics to be stated on the label. The role of associations, in terms of information, is associated with that of certifications, which sometimes coincide, in the sense that there are producers associations (such as Biodyvin) that also issue certifications. Certification also has a purely informative value: it certifies, in particular, the type of practices followed in the vineyard and in the cellar17 . However, even in this case, a certain element of confusion may arise from the large number of certifying bodies, each of which assesses different elements. Therefore, restricting the analysis to the main certifications, we can cite those for organic wine, those for biodynamic wines, and those for 'natural' wines. Organic wine is regulated by European standards, namely Reg. 848/2018 and Reg. 1165/2021. In particular, the certification system is regulated by Art. 34 et seq. of Reg. 848/2018, and is subject to a public control system, as certificates are issued by public entities: 'Competent authorities, or, where appropriate, control authorities or control bodies, shall provide a certificate to any operator or group of operators' (Art. 35 Reg. 548/2018). The European organic wine label is coveted in every sector of the market, even in that of medium or even low-quality wines, as it makes the consumer perceive an added value precisely in terms of quality18 . It has to be said, however, that there is not necessarily a direct relationship between wine quality and organic labelling, as 17 On certifications in the wine sector, there is an extensive scientific literature; see, e.g., D. MOSCOVICI, A.REED, Comparing wine sustainability certifications around the world: History, status and opportunity in Journal of Wine Research, 2018, 29.1: 1-25; M. GIACOMARRA et al. The integration of quality and safety concerns in the wine industry: the role of third-party voluntary certifications, in Journal of Cleaner Production, 2016, 112: 267-274; P. ALONSO GONZÁLEZ, E. PARGA DANS, R. FUENTES FERNÁNDEZ, Certification of natural wine: policy controversies and future prospects, in Frontiers in Sustainable Food Systems, 2022, 6: 875427. 18 E. PARGA DANS, P. ALONSO GONZÁLEZ, A. MACÍAS VÁZQUEZ, Taste and knowledge: the social construction of quality in the organic wine market, in Human Ecology, 2019, 47.1: 135-143 ; G. MAESANO et al. What's in organic wine consumer mind? A review on purchasing drivers of organic wines, in Wine Economics and Policy, 2021, 10.1: 3-21.

the European rules are not particularly strict and therefore also allow producers with a completely conventional approach to obtain it. It can therefore be said that organic certification can create a disharmony between consumer perception and the real quality of the wine, and ultimately even be misleading in the sense of creating expectations of the product that do not correspond to reality. Not only that: the risk is of a tendency to emphasize the Veblen effect, according to which, in contradiction to the laws of classical economics, an increase in price corresponds to an increase in demand. In other words, the Veblen effect is itself evidence of the tendency of consumers to build into their expectations a relationship between organic certification, price and quality, which may in fact be groundless19 . As for biodynamic wine certifications, for them - in contrast to organic wine - there is no public system of rules as well as a commonly accepted universal standard. Certifications, however, are for the most part issued by only two entities (Demeter and Byodivin) whose criteria are substantially similar. The effect of certification for the consumer is, even more so than for organic wine, an increase in the perceived quality index and, consequently, a tendency to pay a higher price20 . I wonder, however, whether this price premium is the result of the perceived quality, the higher cost to the wine producer, or rather the fact that biodynamic wines are particularly sought after by a segment of consumers belonging to the upper-middle socio-economic segment. Some studies, however, suggest that paradoxically, consumers with less knowledge of biodynamic wines tend to have a negative bias towards the labelling of the certification21 . A not dissimilar argument can be made for the most controversial of certifications, that of 'natural wine'. At present, France is the only country in which the indication of 'Vin méthode nature', certified by the Syndicat de 19 M. SIMEONE, C. RUSSO, D. SCARPATO, Price Quality Cues in Organic Wine Market: Is There a Veblen Effect? in Agronomy, 2023, 13.2: 405. 20 P. FANASCH, B. FRICK, The value of signals: do self-declaration and certification generate price premiums for organic and biodynamic wines? in Journal of cleaner production, 2020, 249: 119415. 21 M. DELMAS, Perception of eco-labels: Organic and biodynamic wines, in UCLA Institute of the Environment, 2010, 09-10.

défense des vins naturels, is permitted, although there has been (and still is) controversy over this indication22 . The expression 'natural wine', in fact, is in some respects misleading, for two (paradoxically antithetical) reasons: on the one hand, wine, being the fruit of the fermentation of must by micro-organisms, could by definition be considered a natural product; on the other hand, without the intervention of Man, fermented must tends to acetify, so that wine, from this point of view, would never be a natural product. However, while consumer knowledge of organic wine is sufficiently broad, 'natural wine' is still less well known than biodynamic wine23 . Moreover, even among those who are familiar with the concept of natural wine, there is a tendency towards radicalization, so that there is no direct proportionality between the level of wine knowledge and consumption24 , in contrast to biodynamic wine, although consumers of natural wines appear willing to pay a higher price25 . In any case, it is clear that certification, whether public (such as for organic wine) or private (for biodynamic wines and natural wines) can contribute to the information profile; however, at least for organic wines, there is not necessarily an improvement in the actual information, i.e. linked to a deeper knowledge of the product. To put it another way: for organic wine, labelling lends itself easily to being used for marketing purposes, addressing a broader public that also includes subjects who do not have a deeper knowledge of wine; for organic and natural wine, on the other hand, the greater degree of awareness of the target consumers means that marketing potentially plays a lesser role. 22 P. ALONSO GONZÁLEZ, E. PARGA DANS, R. FUENTES FERNÁNDEZ, Certification of natural wine: policy controversies and future prospects, in Frontiers in Sustainable Food Systems, 2022, 6: 875427. 23 P. ALONZO GONZÁLEZ, E. PARGA-DANS, Natural wine: do consumers know what it is, and how natural it really is? in Journal of Cleaner Production, 2020, 251: 119635. 24 R. VECCHIO et al. Why consumers drink natural wine? Consumer perception and information about natural wine in Agricultural and Food Economics, 2021, 9.1: 1-16. 25 A. GALATI et al. 'Natural wine' consumers and interest in label information: An analysis of willingness to pay in a new Italian wine market segment, in Journal of Cleaner Production, 2019, 227: 405-413.

3. The new Regulation: the problem of nutritional information As mentioned, the wine labelling legislation, previously characterized by the ambiguities I have repeatedly referred to, is destined to change radically with the entry into force, on 8 December 2023, of Reg. 2117/2021. This regulation contains two substantial innovations, announced in recital 42: "In order to provide a higher level of information to consumers, the compulsory particulars under Article 119 of Regulation (EU) No 1308/2013 should include a nutrition declaration and a list of ingredients". Specific provisions are also made for de-alcoholised wines. Understandably, the provision of nutritional information has been among the most contested; in particular, there has been talk of 'criminalizing' wine as an unhealthy product, emphasizing its caloric intake and thus discouraging its consumption. Leaving this aspect aside for the moment, let us see in concrete terms how the nutritional information should be indicated. The new text of Art. 119 of Reg. 1308/2013 establishes the obligation to include the nutrition information, but also specifies that the producer has the option of including only the energy value data on the label, while for the rest "the full nutrition declaration shall be provided by electronic means identified on the package or on a label attached thereto". The European legislator, therefore, has given clear preference to the energy value figure alone, as it is to be expected that few consumers will check the remaining nutritional data via an app or a link26 . This is, in my opinion, a very unsatisfactory choice: on the one hand, the energy value is not the most relevant data related to the consumption of wine; on the other hand, it risks distracting the public's attention from another piece of information, relating to the maximum suggested consumption quantity27 . 26 Moreover, most of these values, according to the definition in Annex I to Reg. 1169/2011, are close to zero: wine contains no significant amounts of fat, protein, fibre, salt. 27 A. ANNUNZIATA et al., Nutritional information and health warnings on wine labels: Exploring consumer interest and preferences, in Appetite, 2016, 106: 58-69, note that consumers generally prefer

It must be additionally be stressed that some studies28 suggest that most wine consumers do not understand the scope and consequences of nutritional information; for example, perhaps due to unfamiliarity, they find it difficult to relate the energy value of wine per 100 ml to the amount of calories taken in through normal consumption, not least because of the variety of sizes of glasses and goblets, which can be misleading (a good-sized goblet, filled half full, can hold 250-300 ml). In my opinion, however, the problem lies precisely in the risk of incorrect assessment of the information provided. In general, the greatest sensitivity to nutritional information belongs to the younger segment, which is more oriented towards assessing the risks of consuming high-calorie foods29 . In the case of wine, however, the energy content is essentially linked to two factors: the alcohol content, and the possible presence of residual sugar. This means, for example, that it is dry wines with low alcohol content that appear more 'virtuous', although they also often have low quality. To give a trivial example, Amarone, considered among the best wines in the world, will certainly have more calories than a wine sold in bric at the supermarket; consequently, there is a risk that the latter type, which is certainly poorer from an organoleptic (and cultural) point of view, will be preferred to the former. If we then relate this to the market segmentation typical of wine, the result will be to steer the less experienced public towards the consumption of lowquality wines, while it is presumable to think that nutritional information will have no significant effect on experienced consumers, who are unlikely to give up product quality for fear of consuming too many calories. data related to the suggested maximum glass size for consumption. R.VECCHIO, A. ANNUNZIATA, A. MARIANI, Is more better? Insights on consumers' preferences for nutritional information on wine labelling, in Nutrients, 2018, 10.11: 1667, suggest instead that consumers prefer a full indication of nutritional elements. 28 E. PABST, G. SZOLNOKI, S.M. LOOSE, The effects of mandatory ingredient and nutrition labelling for wine consumers-A qualitative study, in Wine economics and Policy, 2019, 8.1: 5-15. 29 C. BAZZANI et al, Nutritional knowledge and health consciousness: do they affect consumer wine choices? Evidence from a survey in Italy, in Nutrients, 2019, 12.1: 84.

The effect of the rules, paradoxically, will be to disadvantage that "higher level of information" that the Regulation itself would like to achieve. Moreover, having a fundamentally dis-educative value, as we have seen, the Regulation could even be in conflict with Article 169 of the TFEU, according to which "In order to promote the interests of consumers and to ensure a high level of consumer protection, the Union shall contribute to protecting the health, safety and economic interests of consumers, as well as to promoting their right to information, education and to organise themselves in order to safeguard their interests". In fact, in this case, the apparent greater quantity of information contrasts sharply with its quality, thus contributing to consumer confusion, especially, as we have seen, among those with a lower socio-cultural level. In other words: while there is no doubt that the terms 'information' and 'education' must be read together and constitute a right under Article 169 of the Treaty, they must be able to complement each other30 . If information, from a qualitative point of view, conflicts with the objective of education, it in turn conflicts with the fundamental regulations of the EU. A further risk is therefore to discourage the consumption of quality wine, redirecting the lower end of the market towards cheap products or other beverages (such as beer, which is less calorific than wine because it has less alcohol) and emphasizing the notion of wine as a 'luxury' product31 . Hence my highly critical opinion of the new legislation, which seems to me, mutatis mutandis, to fit in with the general trend towards political correctness that characterizes some recent interventions of the legislator, not only European. 30 E. B. GOLDSMITH, S. PISCOPO, Advances in consumer education: European initiatives, in International Journal of Consumer Studies, 2014, 38.1: 52-61. 31 E. PABST, G. SZOLNOKI, S.M. LOOSE, How will mandatory nutrition and ingredient labelling affect the wine industry? A quantitative study of producers' perspectives, in Wine Economics and Policy, 2019, 8.2: 103-113, provide evidence from a series of interviews with German producers, from which it emerges that they say they are not concerned by the mandatory inclusion of nutritional information, as wine is seen as a luxury product, whose consumer public tends to be indifferent to such information. However, it should be noted that the German wine market is profoundly different from that of countries where wine is the most traditional alcoholic beverage, such as France, Spain, Portugal, Italy etc.

4. The ingredients of wine: an oxymoron? The other side of the intervention made by Reg. 2117/2021 concerns, as mentioned, the indication of ingredients on the label. Previously, as is well known, the only mandatory information in this regard was the alcohol content and the indication 'contains sulphites'. The new Regulation intervenes once again by integrating the provisions of Article 119 of Regulation 1308/2013, in turn referring to Article 9 of Regulation 1169/2011. In practice, the previous differentiation between compulsory indications in the labelling of foodstuffs and in the labelling of wine is abolished. Again, this is without prejudice to the possibility of including information in electronic form, as long as this does not entail the collection or tracking of consumer data (in other words, the information must be provided in a one-way form, from producer to consumer). Furthermore, information on ingredients must not be combined with other information directed at the sale or marketing of the product, and in any case allergens must always be printed on the label (not only sulphites, but, for example, for wines that use egg white in clarification, also eggs). The problem becomes one of imagining how the ingredient information will actually be formulated. According to some simulations made before the new Regulation32 was issued, in most cases it would be indicated that the wine contains 99% grapes, plus a list of additives (preservatives, acidity regulators, stabilizers) and antioxidants (tannin). The problem, evidently, is that the list is scarcely informative, since the model adopted by the European legislator implies, as we have seen, the simple extension of the rules in force for foodstuffs to wine. However, the latter is not entirely comparable to the vast majority of other foodstuffs, being the result of the unique interaction between a natural and a human-induced transformation. 32 S. LA GUERCHE et al., Wine labelling with the list of ingredients: context, consumer's perception and future challenges. Sourced from" Revue Française d'Oenologie n° 308". Original language of the article: English. IVES Technical Reviews, vine and wine, 2022.

To give an example: in food, the addition of an ingredient implies its presence in the finished product. In wine, certain ingredients (sugar, for example) may be added, but will not be found in the finished product, as they have been processed (in this case, into ethyl alcohol). Since Art. 9 of Reg. 1169/2011 refers to the list of ingredients present in the product once it has been put on the market, sugar should not be indicated in this case. However, it is certainly significant for the consumer to know whether the wine has undergone chaptalisation, a practice permitted in many wine-growing areas of the EU. Again: tannin is naturally present when vinification has involved maceration on the skins, but in reality it is simply a component of the grape. It can, however, be added as an oenological practice. Should it be indicated in both cases? And if so, again, is not relevant information for the consumer being omitted? The argument could be extended to other components, such as sulphites or acids (tartaric, naturally present in grapes, can also be added as an acidity corrector), but the point is clear: the simple list of ingredients is on the one hand confusing, and on the other hand absolutely misleading33 . The problem already examined above with regard to nutritional information therefore reappears, if only aggravated: the elements of additional information contribute inversely to the average consumer's understanding of the product's characteristics34 . The consequent risk is to discourage consumption or, at best, to render the information irrelevant (all the more so since, as we have seen, it can be provided by electronic means, and not directly on the label). The last change introduced by the new Regulation concerns the inclusion of the minimum product shelf life date in the case of de-alcoholised wines; given 33 E. PABST, G. SZOLNOKI, S.M. LOOSE, How will mandatory nutrition and ingredient labelling affect the wine industry? A quantitative study of producers' perspectives, in Wine Economics and Policy, 2019, 8.2: 103-113, pointed out producers' fears that ingredient listing could lead to confusion among consumers and thus have a negative effect on sales. 34 E. PABST, G. SZOLNOKI, S.M. LOOSE, The effects of mandatory ingredient and nutrition labelling for wine consumers-A qualitative study, in Wine economics and Policy, 2019, 8.1: 5-15, point out that the inclusion of ingredients in the list tends to condition consumers especially when there is a media campaign about the risks from additives.

the very special market segment of the latter, this is certainly a less relevant profile, at least for the purposes of this essay. 5. Reflections on market segmentation: wine increasingly an elite product? The discussion conducted so far makes clear the non-linearity of the effect of the entry into force of the new regulation. On the one hand, in fact, the declared aim of this is to provide consumers with an effective information tool, to enable them to broaden their choice and to bridge the information gap with producers; on the other hand, the effect of the information - as envisaged by the Regulation - could be to create confusion, especially with regard to the impact of wine consumption on health. I struggle to see any added value in this information. As we have seen, it is essentially irrelevant for the expert consumer, who is certainly more interested in cultivation methods and oenological practices than in sodium content; for the non-expert consumer, it may be difficult to understand and at the same time feed the idea that wine, even that in which there is less human intervention, is a product that tends to be hypercaloric and harmful to health. It is obviously too early to assess what the impact of the new rules will be once they come into force. Perhaps it could be less than expected, as consumers will tend to ignore the new information (which, for the reasons I outlined above, is likely for the list of ingredients, less so for the energy content). There is, however, the possibility that, as a consequence of the new legislation, there may be at least a partial alteration of the segments into which the wine market is traditionally divided. Since the planned additional information, at least in my opinion, is actually of poor quality and informative value, especially as it inappropriately assimilates wine to the generality of foodstuffs, the lower end of the market (discount stores, large-scale distribution) could see reduced consumption, as buyers would be disincentivized by finding that wine, for example, contains more calories than most carbonated soft drinks.

Wine, therefore, especially in some countries, could become even more of an elite product, the prerogative of a public capable of grasping its cultural and organoleptic aspects, neglecting further information, perceived - perhaps rightly - as irrelevant. On the other hand, the trend of a reduction in per capita consumption and a simultaneous rise in average quality has been going on for years. The new Regulation, beyond its intentions, would only consolidate them.