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

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

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