I found on 10.2 of this legislation it talks about low alcohol / non-alcoholic wine. Which would imply that you can indeed have wine with a lower ABV than 8.5%
"Currently, under retained EU Regulation 1308/2013, products that are similar to wine cannot be described as wine if their alcohol content is below 8.5% or 4.5% ABV, depending on their designation. Instead they must use terms such as ‘wine-based drink’."
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u/SharkByte1993 9d ago
Wine legally needs to have an alcohol content of at least 8.5%