The regulatory deadlines, and which of them are actually law

The one that is already law

Since 8 December 2023, wine and aromatised wine products sold in the EU have had to carry a list of ingredients and a nutrition declaration.

The rule allows both to be provided electronically, which in practice means a code on the label. Two things may not move off the physical label: the energy value, and any allergenic substances. The Commission's own condition is that whatever is online has to be as clearly visible and accessible as the information printed on the pack.

It applies to everything from the 2024 harvest onward. Wine produced before 8 December 2023 is exempt until that stock is gone, which is why bottles on the same shelf can be under two different rules.

The instrument is Delegated Regulation (EU) 2023/1606, made under the reform package that Regulation (EU) 2021/2117 sits at the head of. If you have seen the parent number cited on its own, that is the wider reform rather than the labelling requirement itself.

This is the reason wine is the first category we set out to serve. The requirement is in force now rather than at some point in the next few years, it reaches wine from the 2024 harvest onward, and what it asks for is a modest amount of information made reachable from the label.

The ones with dates attached

EU Deforestation Regulation: applies 30 December 2026 to large and medium operators, with micro and small enterprises following later in 2027. It covers cattle, cocoa, coffee, palm oil, rubber, soy and wood, and what it asks for is traceability back to the plot of land a commodity came from. The dates moved once already: the Council signed off a postponement in December 2025.

US FSMA 204: proposed for 20 July 2028, and not final. The Food Traceability Rule's compliance date was 20 January 2026. In August 2025 the FDA published a proposed rule to extend it by thirty months, and the comment period closed that September. We have not seen it finalised, and the source below is the proposal rather than a final rule. If you are planning capital spend against this date, read the rule yourself rather than any summary of it, including this one.

Sunrise 2027 is not one of these

GS1's goal is that retail point-of-sale scanning should be globally capable of reading the GTIN from both linear and 2D barcodes by the end of 2027. GS1 is a standards body, so nothing about it is legally required of anyone.

The guideline that states the goal also states the transition rule that goes with it: until 90% of point-of-sale scanning solutions can use a retail 2D barcode and capture the GTIN from it, a product carrying a retail 2D barcode has to carry a linear one as well. After 2027 a brand may use a 2D barcode only, both together, or the linear barcode only.

Nothing switches off. Sunrise is worth paying attention to because it tells you where retailers' scanner budgets are going, and that is a different kind of information from a date in a statute.

How to tell a deadline from an ambition

Four questions separate them, and the answers are usually one search away.

Who wrote it. A legislature or a regulator writes rules. A standards body writes standards. Both produce documents with dates on them and only one produces penalties.

What its status is right now. In force is not the same as adopted, and adopted is not the same as proposed. The wine rule is in force. The deforestation regulation is adopted with a date. The FSMA extension is a proposal. Each of those is a different amount of certainty about what you will have to do.

Whether the date has moved before. Two of the three above have. A date that has already slipped once is a planning input, not a countdown.

What it actually asks for. These rules ask for information to reach someone. The wine rule is explicit that the information may be provided by electronic means, and none of them names a company, a vendor or a symbology. A code on a label is the cheapest way we know to answer several of them from one place, which makes it a means somebody chose rather than something anybody was told to print.

What is not on this list, and why

Everything above has been checked against the instrument itself or its official announcement, and the sources are at the foot of this page.

Two things you may have seen on other people's timelines are missing. The EU battery passport and the Ecodesign product passports both have dates circulating, and we have not read the legal texts they come from. We are not going to print a date on this page that we have only read about somewhere else, so they are absent until we have. When we have, they will appear here with a source like the ones below.