Sulphites in wine: how to label them in the EU

Why does wine contain sulphites?

Yeasts produce small amounts of sulphites during fermentation, and most winemakers add sulphur dioxide to protect the wine from oxidation and microbes. Wines without added sulphites usually still contain a few milligrams per litre, sometimes more than 10 mg/l.

When must “contains sulphites” appear on a wine label?

When the wine contains more than 10 mg/l of sulphur dioxide or sulphites, expressed as SO₂ (annex II, point 12, of Regulation (EU) No 1169/2011). The obligation applies to all wines placed on the EU market, whatever their vintage.

How do I write it in each EU language?

Use the term set for each language in Delegated Regulation (EU) 2019/33: “sulphites” or “sulphur dioxide” in English, with the equivalent in the official language of each country of sale. A pictogram may accompany the words.

Can the sulphite mention go behind the QR code?

No. Allergens must be printed on the label itself, even when the ingredients list and nutrition declaration are given through a QR code (Regulation (EU) 2021/2117). The e-label page repeats them, highlighted in the ingredients list.

How do sulphites appear in the ingredients list?

As an additive under its category, with the allergen highlighted, for example “preservative: sulphites” or “antioxidant: sulphur dioxide”. The category depends on the function in your wine; many wineries use “preservative”.

How do I show that a wine is below 10 mg/l?

With an analysis of total sulphur dioxide on the finished wine, by a laboratory using a recognised method. Keep the report with the lot. Without it, print “contains sulphites”: the cost of the mention is zero, the cost of a wrong omission is a relabelling.

Does the e-label page have to repeat “contains sulphites”?

Yes, in practice. The ingredients list on the page shows sulphites as an additive with the allergen highlighted, for example “preservative: sulphites”. The printed mention on the label stays mandatory, since allergens cannot be moved behind the QR code.

Do organic wines need “contains sulphites” too?

Yes. Organic rules under Regulation (EU) 2018/848 lower the maximum sulphite levels, but an organic wine above 10 mg/l must still carry the allergen mention, like any other wine.

Is “contains sulfites” in American English accepted in the EU?

The spelling is not the problem; the language is. “Contains sulfites” in English is fine for Ireland or Malta, but a wine sold in Germany needs “enthält Sulfite”, in Italy “contiene solfiti”. US producers exporting to the EU usually add a multilingual allergen line.

What about “no added sulphites” or “sulphite-free” claims?

These are voluntary claims, not EU-defined terms for wine. If you use one, it must be true and not misleading, and it does not replace “contains sulphites” when the wine is above 10 mg/l. We check such claims case by case against your analysis.

Questions from winemakers