WINE LABELLING 179 a. the designation of the category of the grapevine product34; b. the indication of origin (if applicable); c. the indication of provenance35; d. the indication of the bottler or, in the case of sparkling wine, the producer or vendor36; e. the indication of the importer (if any); f. in the case of sparkling wines, the indication of sugar content37; or g. if sparkling wines are obtained by aeration (i.e. added carbon anhydride), this must also be indicated. It is apparent that, while some of the compulsory particulars are undoubtedly of interest to the consumer (especially indications of origin), the EU legislator has taken a minimalist approach – perhaps all too worried that a complete informative approach may lead consumers to confusion. There are likely other reasons implied: typical wine consumers range from those wanting to drink wine simply as an ordinary complement to food (who tend to stand in the lower end of the market) to those seeking wine as a hedonistic product, who are more knowledgeable and less in need of protection38. However, there are rules concerning optional particulars, which extend to: a. the vintage year39; b. the name of the grape variety(ies)40; c. the sugar content (for non-sparkling wines)41; d. the traditional terms (such as vin jaune, cru classé, cerasuolo, etc.)42; e. the Union symbol designating a PGI or PDO, if applicable; 34 As defined in Annex VII, part II of Regulation 1308/2013. 35 The indication of provenance, as specified in article 45 of Regulation 33/2019, refers to the place(s) where the wine is produced, and must be placed on the label for all wines, including those that have no PGI or PDO. A wine may be produced with grapes or must from several countries, in which case this should be indicated on the label. 36 See article 46 of Regulation 33/2019. 37 Sugar content is not indicated in its actual quantity but using traditional terms such as “extra brut”, “brut”, among others, or their equivalent in other languages. 38 Some implications may be found in F. CELHAY & H. REMAUD, What does your Wine Label Mean to Consumers? A Semiotic Investigation of Bordeaux Wine Visual Codes, in Food Quality and Preference, 2018; N. BARBER, J. ISMAIL & D. C. TAYLOR, Label Fluency and Consumer Self-confidence, in Journal of Wine Research, 2007. 39 Provided at least 85% of wine comes from a specific harvest, see article 49 of Regulation 33/2019. 40 If only one variety is indicated, at least 85% of the wine must come from that variety. If two or more are indicated, 100% of the wine must come from those varieties. Different rules apply for wines produced outside of the EU. For wines without PGI or PDO, the Member States may decide to use the indication “varietal wine”, see articles 50 and 51 of Regulation 33/2019. 41 In this case, only 4 terms may be used, compared to 7 for sparkling wines. 42 This only applies to wines with PGI or PDO, see article 120.1(d) of Regulation 1308/2013.
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