I like wine, and I always assumed it would be safe from gluten, milk and egg. However, recently I have started to notice an increased number of wines bearing additional allergen warnings. They still state the usual allergy warning “contains sulphites” but there are now a number of wines with warnings such as may contain egg and milk or “contains gluten”.
Obviously this is very disappointing, but also confusing. Why would gluten, egg and milk be in wine? These allergen warnings are not due to changes in wine making processes, but due to modifications of the labeling legislation which came into force in the EU and UK in 2011.
This article summarizes the relevant processes in wine where allergens are added, chronological amendments of allergen labeling legislation, and the implications for a wine consumer who suffers from Celiac Disease, lactose intolerance, and allergic to eggs.
Winemaking 101: What is Fining?
Winemaking is a complex process in which the resulting liquid requires refining in order to remove unwanted components that can be detrimental to the wines color, aroma and taste1, 2. It is during this refining or ’fining’ that potential allergens can be introduced to wine.
Introduction of Allergens
During the fining process, enzymes are added to the wine. The main method uses a mixture of commercially available enzymes, termed the “kitchen sink” method3. These fining enzymes, or proteins, are by products of either2,5, 25:
- Casein (cow’s milk protein)
- Gelatin (animal protein from collagen)
- Ovalbumin (egg protein from egg whites)
- Conalbumin (egg protein from egg whites)
- Parvalbumin (Isinglass: fish protein from fish swim bladders)
- GBS-P51 and Gluvital 21000 (Wheat glutens)
In the USA and Europe, the Bovine Spongiform Encephalopathy (BSE), or Mad Cow Disease, crisis of the 80’s and 90’s led some winemakers to question the safety of gelatin as a fining agent and to reject the use of animal proteins1, 6. This move led to research into the use of plant-derived proteins as fining agents such as wheat gluten1, 6, 7.
Sulphites (sulfites) is an inclusive term for sulphur dioxide (SO2), also used in the fining process and is the most widely used additive in winemaking. It is mainly used as a preservative, due to its anti-microbial and anti-oxidative properties1, 8, but also as a fining agent to remove unwanted yeast1, 2.
Ageing Wine in Oak Casks
After the fermenting and fining processes are complete, wine is aged before it’s bottled. Subtle flavors are imparted to the wine from the oak casks they are aged in9, different oaks from different regions impart different tones of flavor9. It is at this part of the winemaking process that the wine can inadvertently be contaminated with gluten.
It is standard practice at a number of vineyards to seal the oak barrels with a flour paste to ensure both the staves and the barrel heads have a leak-proof seal3, 4. This does vary by region and vineyard; some wine cooperages use new barrels which don’t require paste while some will use older barrels which have previously used flour paste, reusing the barrel for up to 5-7 years9. Some wineries also use barrel alternatives3, negating the use of flour paste.
Allergen Labeling Legislation
You might ask,if wheat was used in the production of wine, why is it not listed in the ingredients? It is due to the very particular wording of food labelling legislation, specifically what constitutes a “food additive” as apposed to a “processing aid”, the distinction being:
“A substance is a “food additive” if the presence of the substance continues to have a technological function on the finished wine. Thus eggs, milk and fish products used as fining agents would be viewed as processing aids rather than additives provided there are negligible (if any) residues of the fining agent or its by-products in the finished wine.” 2
So whether an ingredient is listed on the label of wine depends on firstly, whether is it classed as an “additive” or a “processing aid” and secondly, the current legislation in place governing the labeling of either. In order to summarize the changes in the governing regulations more succinctly I have broken down the relevant legislation into chronological sections.
The EU legislation specifically governing allergenic foods is the Labeling Directive (Directive 2000/13/EC)10 and its later amendments11. The main legislation implementing the EU food labeling laws in the UK is the Food Labeling Regulations 199612. EU and UK legislation has been designed to make it easy for consumers with food allergies or intolerances to source information regarding the presence of allergens.
In 2003, the Labeling Directive (Directive 2000/13/EC)10 was amended with Directive 2003/89/EC13 which listed 12 allergenic food groups, in Annex IIIa, which had to be clearly indicated on the label of pre-packed foods if they contained any of the following ingredients13:
- Cereals containing gluten (i.e. wheat, rye, barley, oats, spelt, kamut or their hybridised strains) and products thereof
- Crustaceans and products thereof (i.e. prawns, crabs and lobsters)
- Eggs and products thereof
- Fish and products thereof
- Peanuts and products thereof
- Soybeans and products thereof
- Milk and products thereof (including lactose)
- Nuts i.e. Almond, Hazelnut, Walnut, Cashew, Pecan, Brazil, Pistachio, Macadamia and Queensland nut and products thereof
- Celery and products thereof
- Mustard and products thereof
- Sesame seeds and products thereof
- Sulphur dioxide and sulphites at a concentration of more than10mg/kg or 10mg/litre expressed as SO2.
The Directive also stipulated13:
“that additives, processing aids and other substances with allergenic effect covered by Article 6(4)(a) of Directive 2000/13/EC are subject to labelling rules, to give appropriate information to consumers suffering from food allergy.”
This legislation enshrined the concept that all ingredients in the finished food, despite its quantity, should be labelled. This legislation came into force in the UK on November 200414.
This seems straight forward, however, the UK Food Labelling (Amendment) (England) (No. 2) Regulations 200514 implemented Directives 2005/26/EC15 and 2005/63/EC16 establishing a list of food ingredients to be temporarily excluded from Annex IIIa (allergenic food) of Directive 2000/13/EC10. The UK wine sector obtained a temporary exemption from EU regulations on allergens labelling for certain allergenic derivates that, based on the opinions of the European Food Safety Authority (EFSA), were deemed no longer allergenic14, 15. As such, the wine industry did not have to list any of the following ingredients if used as a fining agents, to name just a few15:
Cereals containing gluten:
- Wheat based glucose syrups including dextrose*
- Wheat based maltodextrins*
- Glucose syrups based on barley
- Cereals used in distillates for spirits
- Lysozyme (produced from eggs) used in wine
- Albumin (produced from egg) used as fining agent in wine and cider
- Fish gelatin used as a carrier for vitamins and flavors
- Fish gelatin or Isinglass used as a fining agent in beer, cider and wine
- Whey used in distillates for spirits
- Milk (casein) products used as fining agents in cider and wines
(* denoting exemption only applies if the level of allergenicity of the product has not increased from the processes they have undergone15.)
The only allergen that had to be listed on wine labels from 2005 was:
“Sulphur dioxide and sulphites at a concentration of more than10mg/kg or 10mg/litre expressed as SO2”13.
Directives 2005/26/EC15 and 2005/63/EC16, which established a list of ingredients temporarily excluded from Annex IIIa (allergenic food), expired on 25 November 200715. Products containing these, no longer exempt allergens, were further exempt from labeling until 31 May 2009 due to a transition period, after which time labeling was mandatory14.
Following further EFSA assessment of the temporarily exempt allergens, the European Commission granted permanent exemption status to some of these allergens, as set out in Directive 2007/68/EC17. This directive was implemented in the UK by the Food Labeling (Declaration of Allergens) Regulations 200818. The ingredients which were granted permanent exemption from labeling include17:
Cereals containing gluten:
- Wheat based glucose syrups including dextrose*
- Wheat based maltodextrins*
- Glucose syrups based on barley
- Cereals used in distillates for spirits
- Fish gelatin used as a carrier for vitamins and or carotenoid preparation
- Fish gelatin or Isinglass used as a fining agent in beer and wine
- Whey used in distillates or ethyl alcohol of agricultural origin for spirit drinks and other alcoholic beverages
(*denoting exemption only applies if the level of allergenicity of the product has not increased from the processes they have undergone14.)
Under these new 2008 regulations, the exempt allergens do not have to be indicated on the label with reference to the parent allergen, they do however, still have to be indicated according to the general Food Labeling Regulations 199612. For example, “glucose syrup” will be listed as an general ingredient but it will not have to state the allergen parent “from barley”14. This exemption list came into force in the UK on May 2008. The list may continue to be revised or amended by the European Commission as and when appropriate scientifically validated data (based on the opinion of the EFSA) becomes available, and may involve the addition or deletion of certain ingredients or products14. To complicate matters more, there was a further temporary exemption from labeling for egg albumin used as a fining agent for wine and lysozyme (produced from egg) used in wine until June 201220.
To summarize; after May 2009, fish gelatin and Isinglass do not need to be labelled as present when used as fining agents in wine. Wheat based glucose syrups (dextrose and maltodextrin) and barley based glucose syrups can be used and need only be labelled as “glucose syrup”. Distillates made from whey tend to be spirit alcoholic drinks, not wines29. After June 2012, egg (lysozyme and albumin) and milk (casein) must also be labelled as present when used as fining agents in wine. This explains the sudden appearance of contains egg and milk last year on my favorite bottle of red.
In June 2012, Labelling Directive (Directive 2000/13/EC)10 was again amended, as specified in the amending Regulation 579/201219 for the Labeling and presentation of certain wine sector products. It stipulated that all wines from 2012 vintage onwards which use egg and milk as fining agents in their production must state this on the label, specifically: 19, 20.
From 1st July 2012, one of the following descriptions for wines from 2012 and subsequent harvest must be shown, as set out in the amending Regulation 579/201219, when present >0.25 mg/litre and must be prefixed by “Contains”
- ‘egg’, ‘egg protein’, ‘egg product’, ‘egg lysozyme’ or ‘egg albumin’
- ‘milk’, ‘milk products’, ‘milk casein’ or ‘milk protein’.” 19, 20
but this only applies to:
“wines made completely or partially from grapes harvested in 2012 or later and labelled after 30 June 2012.” 19, 20, 26
These new labels adds to the already in force requirements to state:
“Contains sulphur dioxide” (or sulphites/sulfites), if the finished wine contains more than 10 milligrams per liter of SO220.
The Food Information Consumers Regulation (EU) No. 1169/201121 are currently replacing the Food Labelling Regulations22, 23 and was published in October 201123. The EU Regulation 1169/200121 on the provision of food information for consumers considerably changes existing legislation23. Although published in early 2011, this legislation did not come into force until December 2011 with a transition period of 3 years, therefore not mandatory until December 201421, 23.
The British Retail Consortium (BRC) has released guidance on the allergen labelling requirements that will take effect in 201423 which I have summarized below:
“Contains … milk, gluten” etc. statements will be replaced by one of the following phrases:
“Allergy Advice: For allergens, including cereals containing gluten, see ingredients in bold”
In order to avoid consumer confusion, this allergy phrase will be followed by a potential cross contamination statement23, for example:
“Also, not suitable for customers with peanut allergy”
“Also, may contain soya and egg” or “May also contains nuts”
For example, the new label will look something like this23:
Ingredients: Wheat flour, dried onions, palm oil, dried parsley, skimmed milk powder.
For allergens, including cereals containing gluten, see ingredients in bold. Also, not suitable for customers with peanut allergy.
Not only will there is no requirement to list “gluten”, but all references to it will be removed from the ingredient list. Only the cereal containing the gluten will be listed, for example:
“Contains Barley” 25 or “wheat flour, malted barley flour, …”24, the only exception being if gluten is used as an ingredient in its own right23.
Where there has been a risk of cross contamination by a cereal containing gluten the label will have one of the following allergy advice statements23:
“May also contain gluten”
“May also contain a gluten containing cereal” or
“Also may not be suitable for Celiacs or gluten allergy sufferers”.
These changes to the allergy labeling requirements can be implemented anytime between December 2011 and December 201423.
Detectable Levels of Allergens in Finished Wines
The allergen labeling legislation has also stipulated the maximum level of allergens permitted in a finished wine, before the declaration of that allergen is required. Winemakers test their finished wines for residual levels of fining agents in order assess whether the maximum level has been exceeded. Several studies have investigated the detectable levels of residual gluten in finished wine, I have summarized the studies and their findings below:
Marchal, R. et al.7 investigated the use of wheat gluten as a clarifying agent in red wines and concluded:
“After fining, immunodetection with gluten polyclonal antibodies failed to detect residual deamidated gluten.”
However, a more recent study by Simonato, B., et al.25 (2011) investigated two detection methods of residual levels of gluten in wine. They used commercially used wheat glutens, both partially hydrolyzed (GBS-P51) and nonhydrolyzed (Gluvital 21000) forms using immunoenzymatic analyses using anti-gliadin, anti-prolamin antibodies and liquid chromatography−mass spectrometry as detection methods.
“Residual gluten proteins were detected by anti-prolamin antibodies, anti-gliadin antibodies and sera-IgE only in the wine treated with GBS-P51 at concentration 50, 150, and 300 g/hL, respectively, whereas no residual proteins were detected by these systems in the wine treated with Gluvital 21000.”
“In contrast liquid chromatography−mass spectrometry analyses allowed the detection of proteins in red wines fined down to 1 g/hL of Gluvital 21000 and GBS-P51.”
This detection level equates to 10 ppm of gluten24.
“Our results indicate that mass spectrometry methods are superior to immunochemical methods in detecting gluten proteins in wines and that adverse reactions against gluten treated wines cannot be excluded.” 25
A similar result was found by Tolin et al.26 who investigated Mass Spectrometry detection of egg protein:
“using an immunochemical method residual egg proteins were detected in the experimental red wines only for doses of fining agent of 50 g/hL or higher”
“A simple method based on the recovery and identification of the wine fining proteins by liquid chromatography coupled with tandem mass spectrometry (LC-MS/MS) in a gel-free approach was developed. This allowed the detection of egg proteins in red wines fined down to 5 g/hL”
“These results indicate that the analytical approach here suggested is superior to the immunochemical methods in detecting egg proteins in wines. Therefore hypersensitivity reactions after consumption of wines treated with egg proteins can be a real risk for egg- allergic people.”
Lacorn, M. et al.21 carried out a field study to determine the efficiency of using a commercial egg protein detection kit (assay based kits) and they found:
“different concentrations of egg during fining, but no detectable or low values of ≤1 mg/L in the bottled wine.”
These studies appear to demonstrate that liquid chromatograpy-mass spectrometry is a more sensitive detection method than immunochemical tests. Therefore, depending on what method the winemakers are using to test their finished products it is entirely probable that their wine contains a higher quantity of residual allergens than expressed on the label. The only way to address this would be to implement a consistent and sensitive detection method across all wine producers.
In regards to the ageing of wine in casks sealed with flour paste, there seems to be very little research undertaken regarding the transfer and residual gluten within the finished product. One resource I did find at Gluten Free Dietitian3 tested two bottles of wine for gluten contamination, which had been aged in oak casks. The analysis was performed by Bia Diagnostics using enzyme-linked immunosorbent assay (ELISA). The results concluded that both bottles of wine contained gluten, at a concentration of less than 10 ppm3. Although the gluten content was under the limit of 20 ppm29 and therefore not legally required to be labelled as containing gluten, it is unclear as to why wines aged in oak casks aren’t required to inform consumers of potential allergens. Labeling the wine with “may contain gluten due to manufacturing processes” would inform the consumer of the potential allergen content, even if it is currently deemed safe for consumption by celiacs. Hopefully, the new allergen and cross contamination legislation currently being rolled out will encourage vintners to label their cask aged wines, but only time will tell. Unfortunately, at present the consumer is at risk of low level gluten ingestion.
Recent amendments of EU and UK labeling legislation is compelling vintners to be more transparent regarding the winemaking processes they employ and the potential allergens used. Although these changes are a step in the right direction, they still fall short, leaving the detection methods employed by wine maker unaddressed and unstandardized. The current opinions of food safety groups seem to regard the concentration of residual allergens in finished wine as negligible. However, this opinion appears to be based on research performed using inferior and therefore less sensitive detection methods.
After researching extensively the manufacturing methods of wine and the legislation regarding the labeling, I have been left lacking confidence regarding the safety of drinking wine given my food allergies and intolerances. Obviously those wines labelled “contains eggs, milk, gluten” can easily be avoided but what about wine that only states “contains sulphites”? Without knowing which fining, ageing and detection methods have been employed how can I be sure my wine is actually free from these allergens?
In the UK, only one retailer currently lists the full ingredients in both the wine and the manufacturing process. It isnt until all winemakers fully disclose the allergens used in their winemaking processes, regardless of the residual quantity detected in the finished wine, can the consumer make a true informed decision.
1. Harbertson, J., F. A Guide To The Fining of Wine. Washington State University Extension Manual EM016, Prosser IAREC. https://pubs.wsu.edu/ItemDetail.aspx?ProductID=15179
2. Canadian Vintners Association. Guidance For Fining Of Wine Allergen Labelling. 2012 http://www.sawis.co.za/winelaw/download/GuidanceforFiningofWineandAllegenLabellingJuly2012.pdf
3. Tricia Thompson, MS, RD, Amy Jones, MS, RD, Lisa Almenoff, MS, RD, Luke Emerson-Mason (Bia Diagnostics), Thomas Grace (Bia Diagnostics), Kristin Voorhees (NFCA), Cheryl McEvoy (NFCA) and FA (winery) 2012. Wine Aged in Oak Barrels Sealed with Wheat Paste: Test Results for Gluten Contamination. http://www.glutenfreedietitian.com/newsletter/wine-aged-in-oak-barrels-sealed-with-wheat-paste-test-results-for-gluten-contamination-2/
4. Stavin Barrel System Insert. http://www.stavin.com/barrelsystems/insert.htm
5. Living Without: Hidden Additives and Allergens in Beer and Wine. 2008 http://www.livingwithout.com/issues/2_2/hidden_additives-1318-1.html?ET=livingwithout:p93921:233769a:&st=pmail&s=p_tuesdaytip121112&t=B_TL_P
6. Marchal, R., Marchal-Delahaut, M., Michels, F., Parmentier, M., Lallement, A., and Jeandet, P. Use of Wheat as Clarifying Agent of Musts and White Wines. American Journal of Enology and Viticulture. 2002 Volume 53 No. 4:308-315 http://www.ajevonline.org/content/53/4/308.abstract
7. Marchal, R., Marchal-Delahaut, L., Lallement, A., and Jeandet, P. Wheat Gluten Used as a Clarifying Agent of Red Wine. Journal of Agricultural Food Chemistry. 2002 2,50(1):177-184 http://europepmc.org/abstract/MED/11754564/reload=0;jsessionid=hXX1hv2TdS0E4c3wairc.18
8. Henderson, P. Sulfur Dioxide, Science Behind The Anti-Microbial, Anti-Oxidant, Wine Additive. 2009 http://www.practicalwinery.com/janfeb09/page1.htm
9. Beekman Wines and Liquors. Oak Aging and Wine. http://www.beekmanwine.com/prevtopah.htm
10. Directive 2000/13/EC of the European Parliament and of the Council of 20 March 2000 on the Approximation of the Laws of the Member States Relating to the Labelling, Presentation and Advertising of Foodstuffs. http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2000:109:0029:0042:EN:PDF
11. Food Allergy Information. The EU Labelling Directive http://www.foodallergens.info/Legal/Labelling/Labelling.html
12. The Food Labelling Regulations 1996. http://www.legislation.gov.uk/uksi/1996/1499/contents/made
13. Directive 2003/89/EC of the European Parliament and of The Council of November 2003 amending Directive 2000/13/EC as regards Indication of the Ingredients Present in Foodstuffs. Official Journal of the European Union. http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2003:308:0015:0018:EN:PDF
14. Guidance Notes on the Food Labelling (Amendment) (No. 2) Regulation 2005. The Food Standard Agency. http://www.foodlaw.rdg.ac.uk/pdf/uk-05043-labelling-amend.pdf
15. Commission Directive 2005/26/EC of 21 March 2005 establishing a List of Food Ingredients or Substances Provisionally Excluded From Annex IIIa of Directive 2000/13/EC of the European Parliament and of the Council. Official Journal of the European Union. http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2005:075:0033:0034:EN:PDF
16. Commission Directive 2005/63/EC of 3 October 2005 Corrective Directive 2005/25/EC Concerning the List of Food Ingredients or Substances Provisionally Excluded from Annex IIIa of Directive 2000/13/EC of the European Parliament and of the Council http://www.fsai.ie/uploadedFiles/Dir2005_63.pdf
17. Commission Directive 2007/68/EC of 27 November 2007 amending Annex IIIa to Directive 2000/13/EC of the European Parliament and of the Council as regards Certain Food Ingredients. http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2007:310:0011:0014:EN:PDF
18. The Food Labelling (Declaration of Allergens)(England) Regulations 2008. http://www.legislation.gov.uk/uksi/2008/1188/contents/made
19. Commision Implementing Regulation (EU) No 579/2012 of 29 June 2012 amending Regulation (EC) No 607/2009 laying down certain detailed rules for the implementation of Council Regulation (EC) No 479/2008 as regards protected designations of origin and geographical indications, traditional terms, labelling and presentation of certain wine sector products. http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012:171:0004:0007:EN:PDF
20. Allergens Labelling For Wine. 2012 Food Standards Agency. http://www.food.gov.uk/multimedia/pdfs/enforcement/wineallergenlabel.pdf
21. Regulation (EU) No 1169/2011 of the European Parliament and of the Council of 25 October 2011on the provision of food information to consumers, amending Regulations (EC) No 1924/2006 and (EC) No 1925/2006 of the European Parliament and of the Council, and repealing Commission Directive 87/250/EEC, Council Directive 90/496/EEC, Commission Directive 1999/10/EC, Directive 2000/13/EC of the European Parliament and of the Council, Commission Directives 2002/67/EC and 2008/5/EC and Commission Regulation (EC) No 608/2004 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:304:0018:0063:EN:PDF
22. Business Fact Sheet. Essential Information For Business Success. Allergens Labelling. http://www.norfolk.gov.uk/view/NCC048361
23. British Retail Consortium (BRC) Guidance on Allergen Labelling and the Requirements in Regulation 1169/2011. http://www.brc.org.uk/downloads/Guidance%20on%20Allergen%20Labelling.pdf
24. Winemaking Calculations. Wine Business http://www.winebusiness.com/tools/?go=winemaking.calc&cid=18
25. Simonato, B., Mainente, F., Tolin, S., and Pasini, G. Immunochemical and Mass Spectrometry Detection of Residual Proteins in Gluten Fined Red Wine. Journal of Agricultural and Food Chemistry. 2011 59(7): 3101-3110. http://pubs.acs.org/doi/abs/10.1021/jf104490z
26. Tolin, S., Pasini, G. Curioni, A., Arrigoni, G., Masi, A., Mainente, F., Simonato, B. Mass spectrometry detection of egg proteins in red wines treated with egg white. Journal of Food Control. 23 (2012) 87-94 doi:10.1016/j.foodcont.2011.06.016
27. Lacorn, M., Gobwein, C., and Immer., U. Determination of Residual Egg White Proteins in Red Wines During and After Fining. American Journal of Enology and Viticulture. 2011 Volume 62 No. 3:382-385 http://www.ajevonline.org/content/62/3/382.abstract?sid=b91da1ff-f273-4df1-8660-3e87fafcd8b0
28. Opinion of the Scientific Panel on Dietetic Products, Nutrition and Allergies on a Request from the Commission Related to a Notification from CEPS on whey Used in Distillates for Spirit Pursuant to Article 6 Paragraph11 of Directive 2000/13/EC. http://www.efsa.europa.eu/EFSA/Scientific_Opinion/nda_op_ej483_whey_in_distillates_ceps_en.pdf
29. Food Standards Agency. Guidance on the Composition and Labelling of Foodstuffs Suitable for People Intolerant to Gluten (2012) http://www.food.gov.uk/multimedia/pdfs/glutenguidance2012.pdf