Alcoholic Beverages Labeling in the EU: What Changed and What's Coming in 2026

The EU's approach to alcoholic beverage labeling has undergone its most significant transformation in decades. Since December 2023, wine and aromatised wine products must carry ingredient lists and nutrition information for the first time — a requirement that upended an industry accustomed to being largely exempt from the food information rules that apply to everything else consumers eat and drink.

If you produce, import, or sell alcoholic beverages in the EU, 2026 is a year where you need to understand not just what's already changed, but what's coming next. This guide covers the current regulatory landscape across wine, spirits, and beer — three categories that follow surprisingly different rules.

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The Historical Exception That Ended

For decades, alcoholic beverages over 1.2% ABV enjoyed a broad exemption from the EU's food labeling rules. Under Regulation (EU) 1169/2011 — the Food Information to Consumers (FIC) regulation — beverages containing more than 1.2% alcohol were exempt from both the ingredient list and the nutrition declaration that every other food product had to carry.

The logic was partly historical and partly political: the alcohol industry argued that traditional production methods and complex winemaking processes made standardised ingredient lists impractical. That exemption started crumbling with Regulation (EU) 2021/2117, which amended the Common Market Organisation (CMO) regulation to require ingredient lists and nutrition declarations for wine and aromatised wine products — mandatory since 8 December 2023.

Spirits and beer remain in a different regulatory position, which is why the three categories need to be understood separately.

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Wine: The New Rules Since December 2023

Wine producers have had to adapt to the most comprehensive labeling overhaul in EU wine history. Here's what's now required on every bottle of wine sold in the EU:

Energy value on the physical label: The energy content per 100ml must appear directly on the bottle — in kilojoules (kJ) and kilocalories (kcal). Wine producers may use the shorthand symbol "E" for energy, a derogation not available to other food categories. This cannot be delegated to an e-label; it must be physically printed on the label or back label.

Full nutrition declaration — physical or via e-label: The complete nutrition table (energy, fat, saturates, carbohydrate, sugars, protein, salt per 100ml) is mandatory, but it can be provided electronically via a QR code. This is the e-label provision that generated the most industry discussion. If provided via QR code, the linked page must contain only the nutrition and ingredient information — no marketing content, no sales links, and no user tracking or data collection.

Ingredient list — physical or via e-label: For the first time, wine must declare its ingredients. This includes grapes (which can be listed as "grapes" rather than specific varieties), additives listed by functional category plus E-number or specific name, and processing aids with allergen potential. The detailed rules on how to list wine ingredients are set out in Delegated Regulation 2023/1606. Like the nutrition declaration, the ingredient list can be provided via e-label.

Allergen declaration — on the physical label: This is critical and often misunderstood. While ingredients and nutrition can go on an e-label, allergens must remain on the physical label. For wine, the relevant allergens are sulphites (if >10 mg/L — which is virtually all wine), and any egg or milk-derived fining agents used in production. The declaration must be preceded by "Contains:" in the language of the market.

E-label QR code requirements: If using a QR code for ingredients and/or nutrition, the destination URL must lead to a page that is free of marketing content, does not collect user data, and presents information clearly in the language of the market. Many producers have found this technically challenging — especially managing multi-language landing pages for wines sold across multiple EU markets.

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Spirits: The Voluntary Framework (For Now)

Spirits are governed by Regulation (EU) 2019/787, which sets strict rules for legal names, geographic indications, composition requirements, and compound term usage — but does not yet mandate ingredient lists or nutrition declarations.

The spirits industry has operated under a voluntary self-regulatory framework since 2019, with major industry body spiritsEUROPE committing to provide ingredients and nutrition information via e-labels or physical labels. In practice, adoption has been uneven across the sector.

What is mandatory for spirits right now:

Legal category name: The spirit must be identified by its regulated name from the 44 categories defined in Annex I of Regulation 2019/787. Terms like "Vodka," "Whisky," "Gin," "Rum," and "Brandy" are legally defined — you cannot use them unless the product meets the specific compositional definition.

Compound term rules: If a spirit is used in a product and its name appears in the product description, specific rules apply. The spirit category name must appear in the same font, size, and colour as the rest of the sales denomination — you cannot make "Vodka" prominent while minimising "flavoured drink."

Origin of ethyl alcohol: For spirits that don't have a geographic indication, the origin of the agricultural raw materials from which the ethyl alcohol was distilled must be declared.

ABV declaration: Mandatory, expressed as "X.X % vol." with tolerances of ±0.3% vol.

Allergen declaration: Same rules as wine — sulphites and any other Annex II allergens must be declared on the physical label.

The Commission has signalled that mandatory ingredient and nutrition labeling for spirits may follow, mirroring the wine requirements. The timeline is uncertain, but brands that have already implemented voluntary e-labels will be ahead of the curve.

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Beer: The Industry Commitment

Beer occupies perhaps the most ambiguous regulatory position. It falls under the general FIC regulation's exemption for alcoholic beverages >1.2% ABV, meaning ingredient lists and nutrition declarations are not legally mandatory.

However, the European beer sector (through The Brewers of Europe) signed a Memorandum of Understanding committing to provide ingredient and nutrition information — predominantly via e-labels. The cider and fruit wine sector signed a parallel annex alongside beer and spirits.

In practice, many major breweries now include partial or full nutrition information on their labels or via QR codes, but compliance with the voluntary commitment varies significantly by market and producer size.

What is mandatory for beer:

Allergen declaration — if the beer contains any of the 14 EU allergens (most commonly gluten-containing cereals, and occasionally sulphites). The allergen declaration must appear on the physical label.

Date of minimum durability — mandatory for beers under 10% ABV, which covers the vast majority of the market. The "best before" date must appear on the label.

ABV declaration — mandatory for all beers over 1.2% ABV, in the same field of vision as the product name.

Germany's unique beer requirement: Germany is the only EU member state that requires pre-packaged beer to carry a list of ingredients. This stems from the LMIDV (Germany's national FIC implementation) and the historical influence of the Reinheitsgebot. Imported beers not meeting the Reinheitsgebot must list all non-conforming ingredients. For more on Germany's broader labeling landscape, see our guide on tobacco labeling in Germany, which covers the LMIDV and packaging EPR requirements that affect all product categories.

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The E-Label Revolution: QR Codes on Bottles

The wine industry's adoption of e-labels has been the most visible regulatory innovation in EU food labeling in years. For brands managing labels across multiple EU markets, the e-label provision creates both opportunities and challenges.

The opportunity: A single physical back label with a QR code can serve all markets — the QR code links to a page that detects the user's language and displays ingredients and nutrition in the appropriate language. This dramatically reduces the number of physical label variants needed.

The challenge: The landing page must comply with strict rules — no marketing, no tracking, no sales content. Many producers initially linked QR codes to their existing websites and had to rebuild dedicated compliant pages. The page must also be maintained and updated when the wine's composition changes. Version-controlling your labels across vintages and markets ensures you always know which label version is current and what changed.

The CoLabel connection: This is exactly where dynamic QR codes become powerful. Unlike static QR codes printed on a label, a dynamic QR code lets you update the destination URL after the label has been printed — meaning you can fix errors, update ingredient lists, or redirect to a new compliant page without reprinting labels. For wine producers managing hundreds of SKUs across vintages, this is a significant operational advantage.

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Allergens: The One Rule That Applies to Everything

Regardless of whether the beverage is wine, spirits, or beer, the allergen declaration is always mandatory on the physical label. The EU's 14 mandatory allergens apply, but for alcoholic beverages, the most commonly relevant are:

Sulphites — if present at >10 mg/L. This applies to virtually all wine, most beers with sulphite-containing ingredients, and many spirits.

Egg-derived substances — if egg-based fining agents were used in wine production (common in traditional winemaking).

Milk-derived substances — if casein or other milk proteins were used for fining.

Gluten-containing cereals — relevant for beer and some grain-based spirits. Note: most distilled spirits are considered gluten-free despite being made from gluten-containing grains, because distillation removes gluten proteins. However, if gluten-containing ingredients are added after distillation, declaration is required.

The allergen declaration must use the format "Contains: [allergen]" — with allergens either bolded or otherwise visually emphasised in the ingredient list if one is present.

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What's Coming: The Regulatory Pipeline

Several developments will affect alcoholic beverage labeling across the EU in the coming years. For a broader overview of how these changes fit into the wider EU regulatory landscape across all industries, see our complete guide to EU packaging and labeling regulations for 2026.

Spirits ingredient/nutrition mandate: The Commission is expected to extend wine-style ingredient and nutrition requirements to spirits. When this happens, the voluntary framework will become mandatory, and brands without e-label infrastructure will need to scramble.

Beer sector evolution: If spirits get mandatory requirements, beer is likely to follow. The Brewers of Europe's voluntary commitment may become a transitional framework toward regulation.

PPWR (Packaging and Packaging Waste Regulation): From August 2026, harmonised EU-wide recycling and sorting labels will be required on all consumer packaging — including bottles, cans, and cartons for alcoholic beverages. This means new symbols alongside existing label content.

Ireland's health labeling law: Ireland enacted the Public Health (Alcohol) Act requiring health warnings, calorie information, and cancer risk statements on alcohol labels. While this is a national measure, it may influence EU-level discussions about health-related labeling for alcohol.

Digital Product Passport: The EU's broader ESPR framework will eventually require digital product passports across categories. Alcoholic beverages are not in the first wave (batteries come first in 2027), but the infrastructure — particularly QR-linked product information — is being built now through wine e-labels.

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The EU's alcoholic beverage labeling landscape has split into three speeds: wine has already crossed the compliance threshold with mandatory ingredients and nutrition since 2023, spirits are operating under a voluntary framework that's likely to become mandatory, and beer is watching from the sidelines with industry commitments but no legal obligation yet.

For producers and importers managing labels across this fragmented landscape, the challenge isn't just knowing the rules — it's keeping up as they change. A label management platform designed for regulated industries helps you manage label versions across vintages and markets, compare label versions when regulations update, generate dynamic QR codes that you can update without reprinting, and collaborate with winemakers and designers across your supply chain.