4. Labeling Requirements

Whisky
EU

This section provides information on labeling requirements and the label approval process.

4.1 Mandatory Labeling Parameters

General Food

Requirements set by Article 7 Regulation EU 1169/2011 [1] fully apply in terms of labeling. Other specific EU and/or national provisions may apply depending on the target food/beverage.

Food sold to consumers

Indication of the following particulars is mandatory [1]: 

a) The name of the food (Art 17) - The name of the food shall be its legal name. In the absence of such a name, the name of the food shall be its customary name.

b) The list of ingredients (Art 18) - The list of ingredients shall be headed or preceded by a suitable heading that consists of or includes the word ‘ingredients’. It shall include all the ingredients of the food, in descending order of weight, as recorded at the time of their use in the manufacture of the food. Ingredients shall be designated by their specific name, where applicable, in accordance with the rules laid down in Article 17 and Annex VI (laying down provisions regarding the name of the food and specific accompanying particulars). Specific rules regarding the indication and designation of ingredients are laid down in Anne VII. See also ANNEX VII of the FIC Regulation. Among the exemptions for providing an ingredient list (Article 19): ‘’Cheese’’ made of lactic products, food enzymes, micro-organism cultures, and salt (except fresh cheese and processed cheese) essential to manufacture.

c) Allergens (Art 21) - Any ingredient or processing aid listed in Annex II of the Regulation or derived from a substance or product listed in Annex II causing allergies or intolerances used in the manufacture or preparation of food and still present in the finished product, even if in an altered form shall be emphasized through a typeset that clearly distinguishes it from the rest of the list of ingredients, for example by means of the font, style or background color. 

ANNEX II - SUBSTANCES OR PRODUCTS CAUSING ALLERGIES OR INTOLERANCES

1. Cereals containing gluten, namely: wheat (such as spelt and Khorasan wheat), rye, barley, oats or their hybridised strains, and products thereof, except:
   1. wheat-based glucose syrups including dextrose*;
   2. wheat-based maltodextrins*;
   3. glucose syrups based on barley;
   4. cereals used for making alcoholic distillates including ethyl alcohol of agricultural origin;
2. Crustaceans and products thereof;
3. Eggs and products thereof;
4. Fish and products thereof, except:
   1. fish gelatine used as a carrier for vitamin or carotenoid preparations;
   2. fish gelatine or Isinglass used as a fining agent in beer and wine;
5. Peanuts and products thereof;
6. Soybeans and products thereof, except:
   1. fully refined soybean oil and fat*;
   2. natural mixed tocopherols (E306), natural D-alpha tocopherol, natural D-alpha tocopherol acetate, and natural D-alpha tocopherol succinate from soybean sources;
   3. vegetable oils derived phytosterols and phytosterol esters from soybean sources;
   4. plant stanol ester produced from vegetable oil sterols from soybean sources;
7. Milk and products thereof (including lactose), except:
   1. whey used for making alcoholic distillates including ethyl alcohol of agricultural origin;
   2. lactitol;
8. Nuts, namely: almonds (Amygdalus communis L.), hazelnuts (Corylus avellana), walnuts (Juglans regia), cashews (Anacardium occidentale), pecan nuts (Carya illinoinensis (Wangenh.) K. Koch), Brazil nuts (Bertholletia excelsa), pistachio nuts (Pistacia vera), macadamia or Queensland nuts (Macadamia ternifolia), and products thereof, except for nuts used for making alcoholic distillates including ethyl alcohol of agricultural origin;
9. Celery and products thereof;
10. Mustard and products thereof, except: behenic acid with a minimum of 85 % purity and obtained after two distillation steps used in the manufacturing of the emulsifiers E 470a, E 471, and E 477;
11. Sesame seeds and products thereof;
12. Sulfur dioxide and sulfites at concentrations of more than 10 mg/kg or 10 mg/liter in terms of the total SO2 which are to be calculated for products as proposed ready for consumption or as reconstituted according to the instructions of the manufacturers;
13. Lupin and products thereof;
14. Molluscs and products thereof.

*And the products thereof, in so far as the process that they have undergone is not likely to increase the level of allergenicity assessed by the Authority for the relevant product from which they originated.

d) The quantity of certain ingredients or categories of ingredients (Art 22) shall be required where the ingredient or category of ingredients concerned: appears in the name of the food or is usually associated with that name by the consumer; is emphasized on the labeling in words, pictures or graphics; or is essential to characterize a food and to distinguish it from products with which it might be confused because of its name or appearance. See also Annex VIII.

e) The net quantity of the food (Art 23) shall be expressed using liters, centiliters, milliliters, kilograms, or grams, as appropriate. See also Annex IX.

f) The date of minimum durability or the ‘use by’ date (Art 24). Specificities about how to declare this date are described in Annex X of the Regulation.

(g) Any special storage conditions and/or conditions of use (Art 25) where appropriate.

(h) The name and address of the food business operator, i.e. the operator under whose name or business name the food is marketed or, if that operator is not established in the Union, the importer into the Union market (Art 8).

(i) The country of origin or place of provenance, where failure to indicate this might mislead the consumer as to the true country of origin or place of provenance of the food (Art 26). See also Annex XI. Where the origin of a food is given and is different from the one of its primary ingredient, the origin of the primary ingredient shall be given or at least indicated as being different from the origin of the food.

(j) Instructions for use where it would be difficult to make appropriate use of the food in the absence of such instructions (Art 27).

(k) The actual alcoholic strength by volume for beverages containing more than 1,2 % by volume of alcohol (Art 28).

(l) A nutrition declaration (Art 29 - 36), except for food supplements and mineral waters which gave their own Nutrition declaration provisions. Mandatory nutrition declaration must include all the following particulars (Art 30): energy value and the amounts of fat, saturates, carbohydrates, sugars, protein, and salt. The declaration may be supplemented with an indication of the amount of mono-unsaturated, polyunsaturates, polyols, starch, fiber, or any vitamins or minerals present in significant amounts (as described in points 1 and 2 respectively of Part A of Annex XII of the Regulation).

• The energy value (calculated using the conversion factors listed in Annex XIV) and the amounts of nutrients shall be those of the food as sold. Where appropriate, the information may relate to the food after preparation, provided that sufficiently detailed preparation instructions are given and the information relates to the food as prepared for consumption (Art 31.3).  
• The energy value and the amount of nutrients shall be expressed per 100 g or per 100 ml using the measurement units listed in Annex XV.
• Vitamins and minerals shall be expressed as a percentage of the reference intakes (RI). 
• The energy value and the amounts of fat, saturates, sugars, and salt may be too (RIs are defined in Part A of Annex XIII). In the case of the later, the following additional statement shall be indicated in close proximity to it: ‘Reference intake of an average adult (8 400 kJ/2 000 kcal)’.
• In addition to (in some cases: instead of) the expression per 100g or 100ml, the energy value and the amounts of nutrients may be expressed per portion and/or per consumption unit, easily recognizable by the consumer, provided that the portion or the unit used is quantified on the label and that the number of portions or units contained in the package is stated.

GMO Labeling

Final consumer packaging or pre-packaged products containing GMOs should be labeled: ‘This product contains genetically modified organisms’ or ‘This product contains genetically modified [name of organism(s)]’ [2].

This requirement does not apply to products containing traces of authorized GMOs in a proportion no higher than 0,9% or lower thresholds established under the provisions of Article 30(2), provided that these traces are adventitious or technically unavoidable [3].

In order to establish that the presence of this material is adventitious or technically unavoidable, operators must be in a position to supply evidence to satisfy the competent authorities that they have taken appropriate steps to avoid the presence of such material.

Finally, in addition to the labeling requirements referred to above, the labeling shall also mention any characteristic or property, as specified in the authorization, in the following cases (Article 13.3 of Regulation 1829/2003 [3]):

(a) where a food is different from its conventional counterpart as regards the following characteristics or properties:

1. composition;
2. nutritional value or nutritional effects;
3. intended use of the food;
4. implications for the health of certain sections of the population;

(b) where a food may give rise to ethical or religious concerns.

In addition, the labeling of foods falling within the scope of this Section that do not have a conventional counterpart shall contain appropriate information about the nature and the characteristics of the foods concerned.

Irradiated food/ingredients [4]

In the case of products intended for the ultimate consumer and mass caterers:

1. if the products are sold as items, the words ‘irradiated’ or ‘treated with ionizing radiation’ shall appear on the label.
2. if an irradiated product is used as an ingredient, the same words shall accompany its designation in the list of ingredients.
3. the same words shall be required in order to indicate the irradiated ingredients used in compound ingredients in foodstuffs, even if these constitute less than 25 % of the finished product.

The indication of treatment shall in all cases be given on the documents which accompany or refer to irradiated foodstuffs.

Category

Alcoholic beverages 

The category of "Alcoholic drinks" should comply with the "General Food" requirements described above. Additionally, the below applies:

Requirements set by Article 7 Regulation EU 1169/2011 [1] and Regulation EU 2019/787 [3] fully apply in terms of labeling for spirit drinks. Alcoholic beverages are exempted from declaring the list of ingredients, the nutrition declaration, and the term of minimum durability. Regulation EC 1308/2013 [2] (COM) and other related EU provisions are relevant for wine and wine products.

Where protected geographical indications are used, labeling should comply with the rules, if any, set by the product specifications.

Product

Whisky

"Whisky" should comply with the requirements outlined for "alcoholic beverages" and "General Foods" above. Additionally, the below applies:

The following particulars are always mandatory for Whisky:

• Legal name of the spirit drink as provided by Regulation (EU) 2019/787 [3] (annex I): ‘whisky’ or ‘whiskey’;
• Net quantity of the food;
• Name or business name and address of the food business operator;
• Actual alcoholic strength by volume;
• Lot number.

The following information may be mandatory in certain cases:

• Any special storage conditions and/or conditions of use if necessary;
• The country of origin or place of provenance where failure to indicate this might mislead the consumer as to the true country of origin or place of provenance;
• Instructions for use where it would be difficult to make appropriate use of the food in the absence of such instructions.

Where protected geographical indications are used (e.g. Scotch Whisky, Irish Whisky, etc.), labeling should comply with the rules, if any, set by the product specifications (see further details in Section 4.7 below). 

Warnings and warning pictograms are not currently mandatory at the EU level but, in some Member States, there are national rules to be followed so it is highly recommended to check them country by country. The main warning/warning pictograms (those related to the forbidden intake during pregnancy, during driving, non-adults, etc.) are generally recommended. Further information is available in the Factsheet – Health warning labels on alcoholic beverages [4].

4.2 Languages

General Food

According to Article 15 of Regulation (EU) 1169/2011 [1], mandatory food information shall appear in a language easily understood by the consumers of the Member States where a food is marketed.

Within their own territory, the Member States in which a food is marketed may stipulate that the particulars shall be given in one or more languages from among the official languages of the Union.

Category

Alcoholic beverages 

Same as "General Food" above. Additionally, the below applies:

Article 15 of Regulation (EU) 2019/787 [3] provides that the terms in italics in Annexes I and II (legal names and geographical indications) should not be translated either on the label or in the description and presentation of spirit drinks, except in the case of spirit drinks produced in the Union and destined for export, for which these terms and geographical indications may be accompanied by translations, transcriptions or transliterations, provided that such terms and geographical indications in the original language are not hidden.

Product

Whisky

Same as "Alcoholic beverages" above. Additionally, the terms "whisky" or "whiskey" and related geographical indications (eg. Scotch Whisky, Irish Whisky) should not be translated.

4.3 Mandatory Information on Stickers

General Food

Mandatory information on stickers is acceptable - Article 13 [1]: all mandatory food information shall be marked in a conspicuous place in such a way as to be easily visible, clearly legible and, where appropriate, indelible. It shall not in any way be hidden, obscured, detracted from or interrupted by any other written or pictorial matter or any other intervening material.

Category

Alcoholic beverages 

Same as "General Food" above.

Product

Whisky

Same as "Category" (alcoholic drinks) above.

4.4 Product Legal Name

Product

Whisky

The legal name is "whisky" or "whiskey" as long as compliance with the requirements set by Annex I.2 of Regulation (EU) 2019/787 [3] is guaranteed (see also Sections 2 and 3).

In addition:

• The legal name of "whisky" or "whiskey" may be supplemented by the term "single malt" only if it has been distilled exclusively from malted barley at a single distillery;
• Legal names shall be shown clearly and visibly on the label of the spirit drink and shall not be replaced or altered;
• The legal name may be supplemented or replaced by a geographical indication (e.g. Scotch Whiskey);
• The use of compound terms is also possible. In some cases (e.g. "Scotch Whisky and Honey", "Whisky & Cola"), the legal name of the final product shall be provided along with the compound term; in some other cases (e.g. "Whisky Cream") the compound term is also the legal name;
• The term "dry" is always forbidden for whiskey because all whiskies must be unsweetened.

Furthermore, the legal names of spirit drinks with geographical indications are protected as per Article 26 of Regulation (EU) 2024/1143 [9], for instance, Scotch whisky and Irish whisky. Such spirit drinks are protected against any misuse, imitation, or evocation.

"Geographical indication" means an indication that identifies a spirit drink as originating in the territory of a country, or a region or locality in that territory, where a given quality, reputation, or other characteristic of that spirit drink is essentially attributable to its geographical origin [3].

CJEU judgments are instrumental in clarifying complex concepts such as ‘evocation’. For example, in a CJEU case, a whisky produced in Germany and marketed under the name "Glen Buchenbach" was deemed fraudulent due to its evocation of Scotch whisky. (Case C‑44/17 - Scotch Whisky Association vs. Michael Klotz) [7]).

4.5 Product-specific Labeling Statements

Category

Alcoholic beverages 

Specific labeling requirements (including voluntary statements) are established for different spirit drinks (as provided by Regulation (EU) 2019/787 [3]) and wine products (Regulation (EC) 1308/2013 and related laws). 

Product

Whisky

Other possible voluntary statements are those referring to a particular cask in which whiskey has been matured (e.g. 'Matured in Cognac barrel'). These kinds of statements can only be justified if the spirit drink has been matured in the cask for a long enough period to affect the organoleptic character of that spirit drink. The context in which reference is made to the allusion should be made clear and should only be for the purpose of informing the consumer of the previous contents of the cask used and must be accurate and not misleading. The labeling and marketing of a product should not suggest that all the spirit drink has been matured in the type of cask claimed when that is not the case (it would be misleading to describe a whisky as, for example, ‘Rum cask matured’ if only a proportion of the barrels used to produce the whisky have been matured in rum casks). Finally, the allusion may not be more prominent than the legal name of the spirit drink and the font size used for the allusion may not be larger than that used for the legal name.

Other specific labeling rules:

• As for the other spirit drinks, the name 'whiskey' or 'whisky' (and related geographical indications) may not be used in any way whatsoever on the description, presentation, and labeling of any beverage that does not comply with the production requirements laid down in the whiskey category or geographical indication technical file/product specification (e.g. it is forbidden to use a descriptive name such as 'Whisky-like alcohol-free beverage').
• As for the other spirit drinks, the names of spirit drink categories may be used as part of the reference to a flavoring, or in the presentation and labeling of foodstuffs other than beverages produced by using those flavorings, even if those products do not comply with the requirements laid down for the spirit drink category they refer to in their presentation and labeling. Nonetheless, in order to confer more stringent protection to geographical indications, the legislator has explicitly forbidden that the names of geographical indications for spirit drinks be used to describe any flavorings or foodstuffs flavored with those flavorings. (e.g. 'Scotch Whisky flavored chocolate' must contain authentic 'Scotch Whisky')
• References to 'Low/zero-alcohol' (e.g. 'Non-alcoholic Whisky') are always forbidden.
• As for the other spirit drinks and under certain conditions, the name whiskey/whisky (including related geographical indications) may be indicated in the description, presentation, and labeling of spirit drinks that have been produced by combining different alcoholic ingredients (e.g. 'Black Nail cocktail (Irish Whisky & Irish Mist)').
• As for the other spirit drinks, customary names may be used provided that this does not mislead the consumer. This possibility is reserved for names that are traditionally used in Member States even if they are not formally regulated. Such names (e.g. 'Viski': a term commonly used for whisky in Estonia) may supplement the legal name of spirit drinks placed on national markets where they are accepted by consumers without that name needing further explanation.
• As for the other spirit drinks, the term ‘blend’, ‘blending’ or ‘blended’ (e.g., Blended Whisky) can be used, provided that whiskey has undergone blending in accordance with Article 3, point (11) of Regulation (EC) 2019/787 [3] (blended only with spirit drinks of the same category). For instance, 'Blend of Whisky and Vodka' would be forbidden.
• As for the other spirit drinks, the provenance, other than a geographical indication or trademark, can be indicated in its description, presentation, or labeling, provided that it corresponds to the place or region where the stage in the production process conferred on the finished spirit drink its character and essential definitive qualities took place. The indication of the country of origin or place of provenance of the primary ingredient as referred to in Regulation (EU) No 1169/2011 shall not be required for spirit drinks.

4.6 Authority Approval

General Food

In general, label approval is not provided at the EU level. For some specific food categories, a registration process may be requested at the national level and it may include a label assessment by the authority. 

Category

Alcoholic beverages 

A label approval performed by the authority before putting the products on the market is not provided at the EU level. Geographical indications should be registered according to the procedure established by the European Commission [7] and the related logos should be included on the label and may be subject to control by the national authorities, which are also allowed to check the overall compliance of the label. 

Product

Whisky

Same as "Category" (alcoholic beverages) above.

4.7 Additional Notes on Labeling

General Food

Presentation of mandatory particulars [1]

• Mandatory food information shall appear directly on the package or on a label attached thereto. (Art 12.2)
• Mandatory food information shall be marked in a conspicuous place in such a way as to be easily visible, clearly legible, and, where appropriate, indelible. (Art 13.1)
• The mandatory particulars shall be printed on the package or on the label in such a way as to ensure clear legibility, in characters using a font size where the x-height, as defined in Annex IV, is equal to or greater than 1,2 mm. (Art 13.2)

Voluntary information [1]

Business operators can include as much voluntary information as they want, provided it is not false or misleading (Art 36); however, they cannot do so at the expense of mandatory information. 

Labeling of Organic food [4]

Only products satisfying the requirements set out in the Regulation may be labeled as organic or any other term listed in various languages in the Annex such as “bio” or “eco” (Art 23) or use the Community organic production logo (Art 25) [6].

Process foods can be labeled with the term “organic” or a similar term provided they comply with the requirements set out in the Regulation and at least 95% by weight of their ingredients of agricultural origin are organic.

Mandatory indication

1. The label of Organic food must bear:

1. the code number of the control authority or control body to which the operator that carried out the last production or preparation operation is subject; and
2. in the case of prepacked food, the organic production logo of the European Union shall also appear on the packaging (except in cases referred to in Article 30(3) and points (b) and (c) of Article 30(5)).

2. Where the organic production logo of the European Union is used, an indication of the place where the agricultural raw materials of which the product is composed have been farmed shall appear in the same visual field as the logo and shall take one of the following forms, as appropriate:

1. ‘EU Agriculture’, where the agricultural raw material has been farmed in the Union;
2. ‘non-EU Agriculture’, where the agricultural raw material has been farmed in third countries;
3. ‘EU/non-EU Agriculture’, where a part of the agricultural raw materials has been farmed in the Union and a part of it has been farmed in a third country.

For the purposes of the first subparagraph, the word ‘Agriculture’ may be replaced by ‘Aquaculture’ where appropriate, and the words ‘EU’ and ‘non-EU’ may be replaced or supplemented by the name of a country, or by the name of a country and a region, if all of the agricultural raw materials of which the product is composed have been farmed in that country and, if applicable, in that region.

For the indication of the place where the agricultural raw materials of which the product is composed have been farmed, as referred to in the first and third subparagraphs, small quantities by weight of ingredients may be disregarded, provided that the total quantity of the disregarded ingredients does not exceed 5% of the total quantity by weight of agricultural raw materials.

The words ‘EU’ or ‘non-EU’ shall not appear in a color, size, or style of lettering that is more prominent than the name of the product.

Organic production logo of the European Union

1. The organic production logo of the European Union may be used in the labeling, presentation, and advertising of products that comply with this Regulation.

3. The use of the organic production logo of the European Union shall be optional for products imported from third countries.
4. The organic production logo of the European Union shall comply with the model below (may also be used in black and white):

5. National logos and private logos may be used in the labeling, presentation, and advertising of products that comply with this Regulation.

Code numbers: The general format of the code numbers shall be as follows: AB-CDE-999.

Further details on the requirements for the logo and the code are laid down in Annex V of the organic food regulation [6].

Labeling Relating to Recycling

In the EU, the general principles are laid down for recycling. However, each member state will have variations and different logos/messages and names for their recycling schemes. While specific logos may vary, the overarching message of each recycling scheme is to promote sustainable waste management practices and encourage citizens to participate in recycling efforts to protect the environment.  

Labeling of Halal, Kosher, Vegan

No rules are defined in legislation at the EU level for such labeling.

Labeling of products with protected geographical indication 

Geographical indications are regulated and controlled (for legal name, see Section 4.4 above). In addition, to the general labeling rules, some specific labeling requirements apply, including mandatory logos and indications for EU schemes “Protected designation of origin” (PDO) and “Protected geographical indication” (PGI) are established by Regulation (EU) 2024/1143 [9]. Furthermore, additional specific labeling provisions may be set by the related product specifications.  

Note: Non-EU food can have protected geographical indication, such as Scotch Whisky.

Category

Alcoholic beverages 

Voluntary labeling of nutritional values and ingredients list

Following discussions with the European Commission and the European spirits industry, the industry agreed to voluntarily provide energy values and ingredient lists on labels and/or through QR codes. While this labeling information is not mandatory, foreign business operators are recommended to adopt the same labeling practices as the European industry to offer consumers comparable information. [10]

4.8 References

1. Regulation (EU) No 1169/2011 of the European Parliament and of the Council of 25 October 2011

http://data.europa.eu/eli/reg/2011/1169/2025-04-01

2. Regulation (EU) No 1308/2013 of the European Parliament and of the Council of 17 December 2013 

http://data.europa.eu/eli/reg/2013/1308/2024-11-08

3. Regulation (EU) 2019/787 of the European Parliament and of the Council of 17 April 2019 

http://data.europa.eu/eli/reg/2019/787/2024-05-13h

4. State of play in the use of alcoholic beverage labels to inform consumers about health aspects 

https://health.ec.europa.eu/system/files/2016-11/alcohol_beverage_labels_full_report_en_0.pdf

5. Commission notice-Guidelines for the implementation of certain labelling provisions of Regulation (EU) 2019/787 of the European Parliament and of the Council of 17 April 2019 on the definition, description, presentation and labelling of spirit drinks, the use of the names of spirit drinks in the presentation and labelling of other foodstuffs, the protection of geographical indications for spirit drinks, the use of ethyl alcohol and distillates of agricultural origin in alcoholic beverages, and repealing Regulation (EC) No 110/2008 

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:C_202490029

6. Regulation (EU) 2018/848 of the European Parliament and of the Council of 30 May 2018 on organic production and labelling of organic products and repealing Council Regulation (EC) No 834/2007 

http://data.europa.eu/eli/reg/2018/848/2025-03-25

7. Applications to register new GI products - European Commission

https://agriculture.ec.europa.eu/farming/geographical-indications-and-quality-schemes/registration-name-gi-product/applications-register-new-gi-products_en 

8. Judgment of the Court (Fifth Chamber) of 7 June 2018 - Scotch Whisky Association v Michael Klotz - Request for a preliminary ruling from the Landgericht Hamburg - Reference for a preliminary ruling — Protection of geographical indications of spirit drinks — Regulation (EC) No 110/2008 — Article 16(a) to (c) — Annex III –– Registered geographical indication ‘Scotch Whisky’ — Whisky produced in Germany and marketed under the designation ‘Glen Buchenbach’ -Case C-44/17

https://curia.europa.eu/juris/liste.jsf?num=C-44/17

9. Regulation (EU) 2024/1143 of the European Parliament and of The Council of 11 April 2024 

http://data.europa.eu/eli/reg/2024/1143/oj

10. European Commission Health Promotion and Disease Prevention Knowledge Gateway 

https://knowledge4policy.ec.europa.eu/health-promotion-knowledge-gateway/alcoholic-beverages_en