Wine, beer and spirits are outside the EU passport rule

A bottle of Marlborough sauvignon blanc needs no European Union (EU) digital product passport. Neither does a Central Otago pinot noir, a craft beer or a gin.

European law counts drink as food, and the regulation that creates the passport puts food outside it.

A vendor can sell you a passport system that you do not need

You can spend money and staff time on a duty that does not exist. Some suppliers sell passport systems, and some vendor pages state the EU rules incorrectly. No EU law requires a passport for the drink itself.

Food is excluded, and EU law counts drink as food

The Ecodesign for Sustainable Products Regulation (ESPR) creates the digital product passport. Its Article 1(2) lists the products the regulation does not cover, and food and feed are on that list.

The ESPR does not define food. It takes the meaning from the EU general food law. The table below names both instruments.

The second instrument says this:

'Food' includes drink, chewing gum and any substance, including water, intentionally incorporated into the food

Drink is food. So a bottle of wine, a can of beer and a bottle of gin sit outside the ESPR. Food and feed are excluded covers the wider list, and ESPR exclusions covers the article.

An exclusion is not a delay, because the regulation does not reach the product at all.

The exclusion covers the product, not the company

If you sell pinot noir and also merino jumpers, the pinot noir is excluded and the jumpers are not. A later delegated act may cover the jumpers. Check each product line separately.

The ESPR gives a passport duty to a product group through a delegated act. The European Commission had adopted no such act for any group on 14 August 2026. An act made under the ESPR cannot reach a product that Article 1(2) excludes. Which products need a passport, and when gives the position for every group. How to read the timeline explains why the published sector years are not deadlines.

Your bottle, closure, label and carton are packaging

Packaging is a separate physical good in EU law. The food exclusion does not reach it.

The rule is the Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40. It is in force, and it applies in phases from August 2026. This site publishes no start date for Article 12, the labelling article. The sources behind this site do not confirm that date.

So the wine is outside the ESPR, and the bottle, the closure, the label and the carton have their own regulation. Check that regulation separately. See packaging.

A European buyer can ask for data with no law behind it

A buyer can make product data a condition of purchase. That request needs no regulation behind it, and it carries no legal date. It arrives when the buyer sends the contract.

The Ministry of Foreign Affairs and Trade reported this route in October 2024. It states that EU customers under the EU corporate sustainability due diligence rules may ask you for sustainability information. EU rules reach you by this indirect route. Agree in writing who supplies each item, and who updates it. See agreeing data duties with your EU importer.

EU wine label rules still apply to your bottle

The EU sets label rules for wine in its own instrument. Those rules are separate from the passport, and the food exclusion does not reach them.

Warning: read the last three rows against the amended text, not the original. The Official Journal address for Regulation (EU) No 1308/2013 serves the act as published in 2013. In that original text Article 119 has three paragraphs, it ends at the sugar content, and it names no ingredient list. Paragraphs 119(4) and 119(5) arrived with Regulation (EU) 2021/2117.

If you open the 2013 text and look for Article 119(4), you will not find it, and you may think this page is wrong. Open the amending act as well, or use the consolidated version of the 2013 regulation.

Beer, cider and spirits above 1.2 per cent alcohol by volume need no ingredient list and no nutrition declaration. The wine instrument does not reach them. Other EU food label rules still apply to them.

This site answers questions about the digital product passport. It does not cover the EU wine label rules in full, and the exclusion above answers the passport question alone. Do not read it as a clearance for your label.

A QR code on a wine bottle is not a digital product passport

An EU wine label can carry a QR code that leads to the ingredient list and the nutrition declaration. That page is an electronic label under the wine rules. It is a different thing from a passport, and a different law makes it.

Warning: do not point that QR code at your marketing site. The wine rules forbid sales or marketing information on that page, and they forbid the page to collect or track user data.

A digital product passport is a structured data set about one product, reached from a code on the product. See what is a digital product passport and data carriers. Both a passport and a wine electronic label can use a QR code, so the carrier does not tell you which one you have.

Your work now is packaging and product data, not a passport

1. Stop planning for a passport for the drink. No EU law requires one.
2. Ask your importer which packaging duties it carries, because they are its duties.
3. Answer your buyer's data request from your own records.
4. Find out where your product data lives, and who owns it.

The last step is the real work. If a buyer asks for the specification, the certificate and the origin evidence, one person should produce all three quickly.

See first steps for a New Zealand exporter and what digital product passports mean for New Zealand exporters.