Wine Law

10 ingredients have been limited and mostly expressed by the wine industry rather than by a legal doctrine 30 . Consequently, while a more sensitive approach is certainly needed, it would have at least one caveat. Although there is the need for more complete wine label information being provided for consumers, it should also be acknowledged that it would indeed be difficult 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 certainly cause an undesirable information overload 31 . 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” 32 , 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. These 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 H. S TEINMAN , Wine Ingredient Labeling Poses Problems , available in http://www.winespectator.com/blogs/show/id/48524; P. D RAPER , What’s in a Wine , available in http://www.ridgewine.com/Images/Acrobat/PD_ingredient_letter.pdf; & A. F EIRING , Ingredients on the Wine Label. Absolutely , available in http://www.alicefeiring.com/blog/2014/09/ingredients-on-the- winelabel-absolutely-.html. 31 S. R OLANDI &A. S ABA , Voluntary Certification Systems in the EU Wine Sector: How to Recognize Quality and Be Safe from Confusion , in EDP Sciences, 2015. 32 B. VAN DER M AULEN & E. VAN DER Z EE , Through the Wine Gate. First Steps towards Human Rights Awareness in EU Food (Labelling) Law , in EFFL, 2013; & S. R OLANDI & A. S ABA , Voluntary Certification Systems , cit.