178 WINE LAW the overconsumption of alcohol30. Currently, voices calling for a more complete list of ingredients have been limited and mostly expressed by the wine industry rather than by a legal doctrine31. Consequently, while a more sensitive approach is certainly needed, it would have at least one caveat. Although there seems to be the need for more complete wine label information being provided for consumers, it also be acknowledged that it would indeed be challenging to include all possible ingredients. The list of allowed products and additives – even in organic wine (as defined in Regulation 203/2012) – is intimidating and would undoubtedly cause an undesirable information overload32. Nevertheless, the possibility of using voluntary indications to make labels more informative has caused considerable controversy, especially in the use of terms such as “natural” or “healthy”33, which have been deemed to be misleading. With this point in mind, the fundamental principles regarding wine labelling are set forth in Regulation 33/2019, supplementing Regulation 1308/2013. The latter regulation establishes general rules on common market organisation in agricultural products, whereas the former specifically deals with indications of origin and traditional terms in the wine sector. Additional rules may be found in Regulation 607/2009, which specifies that compulsory particulars and protected geographical indications must be shown in indelible characters that are distinguishable from the surrounding text or graphics (art. 50). Regulation 33/2019 specifies and expands the rules for labelling provided for in articles 117 et seq. of Regulation 1308/2013, which consist of compulsory and optional particulars. As previously stressed, a compulsory list of ingredients is generally limited to alcohol and allergen (i.e. sulphites) content. However, this does not mean that the legislator does not consider other informative compulsory indications, such as: 30 A. ANNUNZIATA, E. POMARICI, R. VECCHIO & A MARIANI, Do Consumers Want More Nutritional and Health Information on Wine Labels? Insights from the EU and the USA, in Nutrients, 2016. 31 H. STEINMAN, Wine Ingredient Labeling Poses Problems, in http://www.winespectator.com/blogs/show/id/48524; P. DRAPER, What’s in a Wine, in http://www.ridgewine.com/Images/Acrobat/PD_ingredient_letter.pdf; A. FEIRING, Ingredients on the Wine Label. Absolutely, in http://www.alicefeiring.com/blog/2014/09/ingredients-on-the-winelabel-absolutely-.html. 32 S. ROLANDI & A SABA, Voluntary Certification Systems in the EU Wine Sector: How to Recognize Quality and Be Safe from Confusion, in EDP Sciences, 2015. 33 B. VAN DER MAULEN & E. VAN DER ZEE, Through the Wine Gate. First Steps towards Human Rights Awareness in EU Food (Labelling) Law, in EFFL, 2013; S. ROLANDI & A. SABA, Voluntary Certification Systems, cit.
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