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.
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