Wine, spirits and alcoholic drinks

• Regulation (EU) No 1169/2011 — food information
• Regulation (EU) 2021/2117 — wine labelling including ingredients and nutrition
• Directive 2020/262 — excise duty general arrangements
• Regulation (EU) No 1308/2013 — market organisation

Who has to appoint one

Anyone placing alcoholic drinks on the EU market. Two separate systems apply at once: food law for composition and labelling, and excise law for duty, which requires movement under duty suspension between authorised warehouses or payment in the member state of destination. Distance sellers to consumers must appoint a tax representative in the destination state in most member states.

Thresholds and exemptions

No threshold. Distance selling of alcohol to consumers triggers destination-state excise from the first bottle, and several member states also require licences to sell alcohol at all.

What must appear on the label

Name, net quantity, actual alcoholic strength by volume, lot number, allergens, the EU operator's name and address, and since December 2023 for wine the ingredient list and nutrition declaration, which may be provided electronically via a QR code with the energy value on the physical label. Health warnings are mandatory in Ireland from 2026 and are being considered elsewhere.

Marketplace fields

Most marketplaces restrict or prohibit alcohol sales, and those that permit them require licences, age verification and proof of excise arrangements. Cross-border consumer sales are the most commonly misunderstood part of the regime.

Documentation you must hold

Food business registration. Excise registration as authorised warehousekeeper, registered consignee or tax representative. Electronic administrative documents for duty-suspended movements. VI-1 or equivalent documents for wine imports. Analysis certificates and, for wine, the product specification where a protected designation is used.

Standards and testing

Alcoholic strength verification, allergen analysis for sulphites above the threshold, and contaminant testing per product. Protected designation products require compliance with their specification.

Language requirements

The entire label in the language of each member state of sale, including the ingredient and nutrition information where provided on-label.

When it applies

Excise arrangements before the goods move. Labelling before the first sale. Wine ingredient and nutrition rules apply to wine produced from the 2024 harvest onwards.

How long records are kept

Excise and traceability records per national law, generally at least five to ten years.

What happens if you do not comply

Seizure of the goods, excise assessments with penalties and interest, and criminal exposure for duty evasion, which is treated far more seriously than a labelling error. Consumer sales without a tax representative are the most frequent finding against foreign online sellers.

Who enforces it

National customs and excise authorities, food safety authorities, and in the wine sector the dedicated control bodies.

Where the boundary lies

Excise is the trap: shipping wine to a consumer in France from outside France means French duty, a tax representative and, in practice, a logistics partner set up for it. Product law compliance does not cure an excise failure, and the two are enforced by different authorities.

Questions we are asked

Can we ship wine directly to EU consumers?

Only with destination-state excise arrangements, which in most member states require a tax representative established there. The bottle being legal does not make the shipment legal.

Does the new wine labelling apply to our stock?

It applies to wine produced from the 2024 harvest onwards; earlier stock may be sold under the previous rules until exhausted.