Since 8 December 2023, wine sold in the EU has had to carry a list of ingredients. Most producers got the nutrition declaration sorted first, because the arithmetic is finite and the answer is a number. The ingredients list is harder in a different way: nothing about it is arithmetic, and the mistakes are all judgement calls made once and then printed ten thousand times.
Here is how to build one that survives a look from a control authority.
Start with what an ingredient actually is
An ingredient is any substance used in making the wine that is still present in the finished product, even in an altered form. That last clause does most of the work.
A substance used to do something during production and then removed is a processing aid, and processing aids do not go on the list. Bentonite added for protein stability and racked off. Gelatine or isinglass used to fine a wine and then filtered out. The nitrogen you sparge with. None of those are ingredients.
The line is presence, not intent. If a fining agent is fully removed, it is an aid. If a stabiliser is added to stay in the bottle — metatartaric acid, gum arabic — it is an ingredient, and it goes on the list.
The order: descending weight, at the moment of use
Ingredients are listed in descending order of the weight they contributed when they were used. For almost every wine that produces the same opening word:
Grapes, ...
Then everything else, largest to smallest. In practice, after grapes you are ordering milligram-per-litre additions against each other, which is why most lists follow a familiar shape: the concentrate or must used for sweetening if any, then acidity regulators, then the preservative, then the stabilisers.
Two details catch people out:
- Grape must and concentrated must used for sweetening are ingredients, and they are usually the second-largest item by a wide margin.
- Water used to dissolve an additive is not declared separately.
Naming: functional category first, then the substance
Additives are not named on their own. Each one is preceded by the functional category that says what it is doing in the wine, and then identified by its specific name or its E number:
Preservative: potassium metabisulphite
Acidity regulator: tartaric acid
Stabiliser: gum arabic
Either the name or the E number is acceptable — Preservative: E 224 is as valid
as Preservative: potassium metabisulphite. Producers exporting into several
markets often prefer E numbers because they travel without translation. Producers
selling direct to consumers usually prefer the names, because E 224 on a
natural-leaning label reads worse than what it actually is.
Pick one convention and hold it across your whole range. A portfolio where half the wines say potassium metabisulphite and half say E 224 looks like two people wrote the labels, because two people did.
Allergens are a separate obligation
The ingredients list and the allergen declaration are different requirements that happen to overlap, and conflating them is the most common structural mistake.
Sulphites above 10 mg/L, and any milk- or egg-derived product that leaves a detectable residue, must be declared on the physical label. That obligation does not move behind a QR code, no matter how complete your e-label is.
So a wine fined with egg white and bottled with 60 mg/L total SO₂ carries
Contains sulphites and an egg-derivative mention on the bottle — and the same
substances appear again in the ingredients list, in their ingredient form and
position. Saying it twice is correct. Saying it only in the e-label is not.
What the finished list looks like
A dry white, fined and stabilised, sweetened with nothing:
Ingredients: Grapes. Acidity regulator: tartaric acid. Preservative: potassium metabisulphite. Stabiliser: gum arabic.
An off-dry rosé sweetened with concentrated must:
Ingredients: Grapes, concentrated grape must. Acidity regulator: citric acid. Preservative: potassium metabisulphite. Stabilisers: gum arabic, metatartaric acid.
A traditional-method sparkling wine, where the liqueurs are their own story:
Ingredients: Grapes, sucrose, grape must. Preservative: potassium metabisulphite. Yeast.
Note the sparkling example: the sugar in the tirage and dosage liqueurs is an ingredient, and so are the yeasts, because they are present in the finished wine.
Where it lives, and why that matters
The full ingredients list may be provided electronically — that is the whole point of the e-label. What has to stay printed is the energy value, the allergen declaration, and the other mandatory particulars that were always there.
Two conditions come with moving it electronically. The page carrying the mandatory information must not present marketing or commercial content, and it must not collect or track consumer data. A general product landing page with a newsletter signup and an analytics tag on it does not qualify, however well it describes the wine.
Doing it once per wine, not once per label version
The practical problem is not writing one ingredients list. It is that a producer with thirty references and four vintages in circulation has a hundred-odd lists, each pinned to a specific bottling, and every one of them has to keep matching a QR code printed on glass.
That is the case for holding ingredients as structured data against each product and vintage rather than as a text block in a design file: the label artwork, the e-label page and the technical sheet all read from the same record, and a correction is made once. Which is roughly what Drinksbase exists to do — but the discipline matters more than the tool. Whatever you use, the ingredients list should have one home, not four copies.
Before you send artwork to print
- Every substance still present in the finished wine is on the list.
- Nothing that was fully removed is on the list, unless it leaves an allergenic residue.
- Order is descending by weight at the moment of use, grapes first.
- Every additive carries its functional category, and the naming convention is consistent across the range.
- Allergens appear on the physical label, in addition to the ingredients list.
- The e-label page carries no marketing content and no tracking.
- The QR code resolves to a URL on a domain you control, and will still resolve in ten years.
