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.
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