Energy calculation

New rules for nutrition declarations on labels

Wines, completed after 8 December 2023, must have a declaration of Ingredients and Nutritional content per 100 ml.

Declaration on the wine label or by using QR codes?

If you can find space on the wine label (or back label) for the nutrition declaration, it is by far the simplest method! Here you must display the required content and meet the font size and language requirements.
If there is no space on the label, a QR code can be inserted on the label instead, which directs the consumer to a website where the data can be found.

The rules for the design of the electronic declaration can be found in Ordinance 251/2014-6a (link at top). One of the significant restrictions is that the consumer must not be exposed to sales/marketing and tracking on the site. This can be accomplished in several ways.
Either you can use web services for this, so that the information is not on the manufacturer's website together with e.g. marketing info, – it costs an annual subscription for each product throughout the product's lifetime. Or you can copy the solution we practice here on our website.

Q/A Guide (item 30) interprets the requirement that the consumer must not be exposed to sales/marketing etc. as meaning that you cannot have the electronic nutrition declaration on the manufacturer's website:

“… After the Commission's perception seems the presentation of this mandatory information as part of the manufacturer's website not to meet the conditions of Article 119, paragraph 5, since a wine producer's website typically expected to contain commercial information that is relevant for marketing and/or sales. Also, websites track normally information about the users.”
(Our emphasis in italics.)

But one thing is the interpretation; – something else is the rules.
Article 119, subsection 5b says: "the list of ingredients shall not be displayed with other information intended for sales or marketing purposes;".
The rule does not say anything about where the nutrition declaration must be - or must not be.

Our QR code links to a product page (on our website) that is completely naked – without header, footer and menus to other pages. There is only one language menu, as the information must be presented in the languages ​​that are relevant in the countries where you sell your wine.
The only tracking that takes place on our website is the traffic count carried out by the web host and Google Analytics. No personal information is stored here. This also happens when using the recommended web services.
If you go to the product page from our overview page "Our wines” (and thus already has access to our complete menu), then opens, among other things, for the backlink at the top of the page (so you can get back to the rest of the website – and the main menu) and a subjective description of the wine at the bottom of the page – on exactly the same page. (It requires some programming of the website.)

In addition, it is permitted (cf. the label examples in the below-mentioned article in Vinpressen) that the address on the producer's website is printed a few millimeters below the QR code on the label.

If the customer wants to find the manufacturer's website, it is easy. – Either by Googling the wine or studying the other information on the wine's label.
So why be forced to pay for an unnecessary web service if it cannot prevent the consumer from finding the manufacturer's website after all. There simply must not be direct access to sales/marketing by using the QR code for the nutrition declaration.

Example:
1) Link from QR code: https://www.vrangbaekgaard.dk/2022-raadhusklokken/ (no parameters in the QR link)
2) Link from the overview page: https://www.vrangbaekgaard.dk/2022-raadhusklokken/?show_all=true, (the parameter opens the hidden sections)
It is our interpretation, that this is OK in relation to the legal text, even if it does not follow the Q/A instructions.
You can get to our website by manually editing the address in the browser's address field, but this is no different from entering the website address, which can be found printed elsewhere on the label.

Others are welcome to be inspired, but must themselves be responsible for their chosen solution.

Examples of web services: Sip label, ScanForFacts and PinotQR.
Guide for using the QR codes on labels prepared by ScanForFacts in collaboration with Sven Moesgaard, Skærsøgaard:
https://scanforfacts.io/quick-guide-on-presenting-nutrition-ingredients-for-wines/
Article about the nutrition declaration and QR codes in Vinpressen: Vinpressen 2024-1 (Sven Moesgaard).

Regardless of which solution you choose to use, the nutrient content must be calculated:

Calculation of the necessary values ​​for the nutrient content

The most important part of the total energy content comes from the alcohol. Next, there may be some residual sweetness if the yeast has not fully fermented or if liqueur has been added during the adjustment of sparkling wines. And finally, some glycerol is formed during fermentation.
The glycerol can be difficult to measure without advanced measuring equipment, but since it is formed in parallel with the yeast converting the sugar into alcohol, it can be estimated as 6% of the amount of alcohol formed. This factor is found as an average of many Winescan measurements on different wines. The uncertainty is expected to correspond to the uncertainty of Winescan's glycerol calibration, - and since the glycerol makes up a very small part of the total energy, the estimated value is sufficiently good for use on the label.

In the calculation below, a distinction is made between "total alcohol" and "fermented alcohol". In the case of a 'normal' fermented wine, the two values ​​will be equal. But by e.g. a fortified wine of the port type, the fermentation is stopped after a few days by adding pure alcohol until the desired total alcohol percentage is reached. For the energy calculation, the total alcohol percentage must be used, while the alcohol percentage the yeast had reached when it was stopped must be used for the glycerol calculation.