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
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