New Zealand Winegrowers Labelling Guide 2013

New Zealand Winegrowers Labelling Guide 20th Edition March 2013

New Zealand Winegrowers Labelling Guide 20th Edition March 2013

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INTRODUCTION

DISCLAIMER

The wine label is an integral part of every winegrower’s business identity. Designing a wine label can be a real challenge. Not only does it need to look good and be effective in communicating your message, it also needs to comply with all the legal requirements for wine labels. Legal compliance becomes even more of a challenge when you are exporting to multiple markets.

New Zealand Winegrowers provides three tools to assist members with the difficult task of designing labels to meet different market requirements:

Information in this document is prepared by New Zealand Winegrowers for use by members of the New Zealand Grape Growers Council and the Wine Institute of New Zealand only.

Material may not be published or reproduced without permission of New Zealand Winegrowers.

• A quick reference poster which gives the requirements of major markets at a glance; • A web tutorial which can be found on the www.nzwine.com website; and • The Labelling Guide which provides more detailed information and more market coverage.

We recommend that wineries use all three tools to ensure that their labels are based on the best and broadest information available.

If any aspect of the information contained in this guide is unclear, or you have additional questions, members can contact the New Zealand Winegrowers Advocacy team either John Barker on john@nzwine.com or Olivia Grainger on olivia@nzwine.com for further assistance.

This document represents our interpretation of the labelling regulations of various countries as at February 2013, based on legislative texts, guidance material and discussions with regulators. All due care and attention has been exercised in the preparation of the information contained in this document.

However, labelling regulations will change over time, and interpretations may differ between regulators. We will endeavour to provide regular updates on labelling matters as they come to hand. Nevertheless, this document is not intended to be the definitive source on wine labelling matters, as this will always be in the hands of the regulators who administer them. Nor is it intended to be a substitute for detailed legal advice in specific cases.

This information is provided strictly on the basis that New Zealand Winegrowers, the Wine Institute of New Zealand Inc, the New Zealand Grape Growers Council Inc and their officers, employees or agents disclaim any liability of any kind for any inaccuracy, error, omission or other flaw in the information contained in this document, and for any loss and/or damage that may arise from reliance on the information presented.

NEW ZEALAND INTERNATIONAL LABELLING GUIDE 20TH EDITION I MARCH 2013

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TABLE OF CONTENTS

DESIGNING A WINE LABEL: THE BASICS

3

NEW ZEALAND New Zealand labelling laws

5

Mandatory Information

5

Optional information

6

What else you should know

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AUSTRALIA

OTHER ASIAN COUNTRIES Hong Kong

27

Thailand

27

Malaysia

27

Singapore

27

India

28

Taiwan

28

Philippines

28

Indonesia

28

Australian labelling laws

9

Mandatory Information

9

Optional information

9

ANNEX 1

EU labelling laws

10

ANNEX 2

Mandatory information

10

Geographical Indications for use in the EU and Brazil

Optional information

12

Appellations of origin for use in the USA

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EUROPEAN UNION (EU)

Annex 3

UNITED STATES OF AMERICA United States labelling law

15

Mandatory information

15

Optional information

16

CANADA Canadian labelling laws

18

Mandatory information

18

Optional information

19

EU Allergen Declarations

Chinese labelling laws

20

Mandatory information

20

Optional information

21

JAPAN

31

Annex 3A Permitted Languages/Translations (Sulphites)

31

Annex 3B Permitted Languages (Milk/Egg)

32

Annex 3C Permitted Wording (Sulphites/Egg/Milk)

CHINA

33

Annex 3D Pictograms (Sulphites/Egg/Milk)–

34

Annex 4

Japanese labelling laws

22

Sparkling Wine

34

Mandatory information

22

USA

34

Optional information

22

EU

35

China

37

SOUTH KOREA South Korea’s labelling laws

23

Mandatory information

23

Optional information

24

RUSSIA Russian labelling laws

25

Mandatory information

25

BRAZIL

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Brazilian labelling laws

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Mandatory information

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DESIGNING A WINE LABEL: THE BASICS

When you are designing labels for a wine that will be sold in multiple markets, there are 5 key points to keep in mind: 1. You can design a single front label that will work for most major markets 2. You will need to change your back label for each different market (except Australia) 3. For some markets, you will need a special language label 4. For vintage, variety and geographical indication, the most restrictive rules apply 5. Special wines have special rules 1. THE SINGLE FRONT LABEL There are two options for a front label that can be used in all major markets:

You can meet all of you legal mandatory information requirements on the back label, leaving the front label “clean”.

Clean front label Legal back label (NZ/AUS)

MARLBOROUGH SAUVIGNON BLANC 2013

• The front label is not so clean but it frees up space on the back label • This option does not work for Canada because the authorities require mandatory information to be presented in translation on the front label • If you are using this option in the USA, the back label needs to be designated the “Brand Label” • If you are using this label in the EU, you should print the SFOV information again on the back label since this needs to be on the same label as the importer details • You can put other legal mandatory information on the front as long as it is repeated in the correct legal form on the back label 2. CHANGING THE BACK LABEL

The “clean” front label

John’s

Some important points if you are using this option:

JOHN’S WINERY 52 SYMONDS STREET AUCKLAND

New Zealand WIne Contains approx 7.7 standard drinks Contains Sulphites Produced with egg whites, traces may remain

Alc. 13% Vol

750 ml

Some important points if you are using this option: • This is the best option to cover all English language markets • This option does not work for Canada because the authorities require mandatory information to be presented in translation on the front label • If you are using this option in the USA, the back label needs to be designated the “Brand Label” • You can put “single field of vision” (SFOV) information on the front as long as it is repeated in the correct legal form on the back label

The back label needs to be changed for every market (except Australia which accepts legal NZ labels).

Why? Because every country requires that the importer in their territory is listed on the label to ensure traceability. Plus, most countries will have their own unique requirements which aren’t compatible with other countries – like NZ’s standard drinks.

Some people try to manage this by printing back labels with a blank space so they can add in different country requirements later. Others have tried to list the importers for each different market on the same label, but this takes up space and doesn’t get you into very many markets.

3. SPECIAL LANGUAGE LABELS Some markets like China, Japan and Russia require the label to be presented in local characters. Canada requires some information to be presented in French and English. In these cases, it is best to produce a special label for the market. This should be done in consultation with your local distributor or importer to make sure you get it right.

The special label doesn’t need to be fancy. They just need to capture the legal essentials. Generally overstickers are not looked upon favourably at an official level even though they are widely used.

The “single field of vision” front label You can put on the front label those items of legal mandatory information that most countries accept when presented in a “single field of vision” – i.e. product name, country of origin, alcohol by volume, net contents.

SFOV front label Legal back label (NZ/AUS)

John’s

JOHN’S WINERY 52 SYMONDS STREET AUCKLAND

MARLBOROUGH SAUVIGNON BLANC 2013

Contains approx 7.7 standard drinks

NEW ZEALAND WINE Alc. 13% Vol 750 ml

Contains Sulphites Produced with egg whites, traces may be present

4. FOR VINTAGE, VARIETY, GEOGRAPHIC INDICATION, THE MOST RESTRICTIVE RULES APPLY For vintage, variety and geographic indication, the NZ rules are the baseline. You must always comply with these as a minimum.

But if an export market has more restrictive rules than NZ, you must follow those rules as well as the NZ rules.

The only exception is a single grape variety statement in the USA where a 75% minimum is permitted rather than the NZ 85% minimum.

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5.

SPECIAL WINES HAVE SPECIAL RULES

Sweet wines, sparkling wines, fortified wines, wines with high alcohol, wines in non-standard packages – all of these may be subject to special labelling rules. These may include: • special names that must be used on the label • additional mandatory information such as sweetness level • different type size requirements The Labelling Matrix covers standard wines in a 750ml bottle only so you should not rely on it when labelling special wines.

You will need to consult the Labelling Guide and possibly also the Winemaking Practices Guide when labelling these products.

Dos and Don’ts

• Do check your labels with your offshore distributor. They may have special requirements or information about the market. Plus it helps to share the responsibility if anything goes wrong.

• Don’t use positive health claims. These are not permitted in most markets.

• Do consider using the “Cheers!” logo in the NZ market and/or a pregnancy advisory logo or statement – depending on the rules in the importing country.

• Don’t make sustainability or organic claims that can’t be substantiated by accreditation to a reputable scheme.

Regulators increasingly want to see evidence to support environmental labels and for organic claims in some markets an official assurance is needed.

• Do get in contact with John Barker on john@nzwine.com or Olivia Grainger on olivia@nzwine.com if you have any questions.

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NEW ZEALAND

New Zealand labelling laws

Net Contents

The main laws governing the labelling of wine for sale in New Zealand are the:

A wine label must include a statement of the net contents, expressed as litres, decilitres, centilitres or millilitres (e.g. 750 ml).

This statement should be:

• Food Act 1981 • Australia New Zealand Food Standards Code

• at least 2mm in height

• Food (Safety) Regulations 2002

• placed in a prominent position (front or back label)

• Weights and Measures Regulations 1999

• in close proximity to the name of the product

• Wine Act 2003

• in a colour that contrasts distinctly with the background (R.79, Weight & Measures Regs 1999)

• Wine Regulations 2006 • Wine (Specifications) Notice 2006

Producer

• Fair Trading Act 1986

A wine label must include the name and business address in New Zealand or Australia of the supplier (Standard 1.2.2).

Copies of all of these laws can be found on the Government’s legislation website www.legislation.govt.nz. The Food Standards Code can be found at www.foodstandards.govt.nz.

Mandatory information

The “supplier” may be the producing winery, packer, vendor or importer. The address should be a physical address. Note that the person named on the label is presumed to be responsible for the product and will be legally liable for that product under the Food Act 1981.

Presentation And Placement With the exception of “net contents”, there are no minimum type size or placement requirements for any of these mandatory items, although they must be in English and presented legibly and prominently such as to afford a distinct contrast to the background (Standard 1.2.9).

Sulphite Declaration

Product name

A wine label must include a sulphite declaration if it contains more than 10 mg/kg of sulphur dioxide. The form of the statement is: “contains preservative 220”, “contains sulphites”, or “contains sulphur dioxide”. This is not a “warning statement” in terms of the Food Standards Code, and the type size requirements therefore do not apply.

A wine label must include a name or description that indicates the true nature of the food (Standard 1.2.2). For wine, this can be:

Allergen Declaration

• the word “wine” • the type of wine (e.g. “sparkling wine”, “white wine” etc) • a variety name • a generic name such as Port Country of Origin A wine label must include a statement indicating the country of origin (e.g. “New Zealand wine”, “Product of New Zealand”) (Standard 1.1.3A). If any of the grapes, grape juice, concentrated grape juice or spirit used in a wine originates in another country, then that must also be included on the label - i.e. you cannot use imported concentrated grape juice unless you are prepared to acknowledge it in the country of origin statement.

A wine label must include an allergen declaration if milk or egg products, fish products (except for isinglass) or other allergens1 are present (Standard 1.2.3). Isinglass is exempted from this requirement.

Testing for milk and egg residues in wine is now available in New Zealand. If no residues are detected on analysis, then our view is that it should not be necessary to label for their presence even if they have been used in production. For producers who do not want to test wines that have been fined with such products, a “may contain” statement is allowed.

The form of the labelling requirement is not specified in legislation. The following forms of declaration were suggested in legal advice from Bell Gully: • “[Milk/Egg] products have been used as a fining agent in the manufacture of this wine. Traces may remain.”

Alcohol by volume A wine label must include an alcohol declaration (Standard 2.7.1).

The acceptable form for the declaration is “ml/100g” or “ml/100 ml” or “x% alcohol by volume” or words or expressions of the same or similar meaning: i.e. “% vol” will suffice.

• “Fining agent: [milk/egg] products.”

• “[Milk/Egg] products have been used to purify this wine, in accordance with traditional winemaking techniques. Traces may remain.”

Tolerances of the declared alcohol content from that actual alcohol content are: • fortified wine +/– 0.5%.

• wine and sparkling wine +/– 1.5%.

Cereals containing gluten and their products, crustacea and their products, peanuts and peanut produts, sesame seeds and sesame seed products, soyabean and soyabean products, tree nuts and tree nut products.

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The following additional forms of declaration were developed by the Australian Wine and Brandy Corporation in consultation with Food Standards Australia New Zealand. If exporting to Australia, it may be preferable to use these forms: • “Produced with casein (milk product)” • “Contains/produced with milk product” • “Produced with casein (milk product). Traces may remain” • “Produced with milk products. Traces may remain” Standard drinks A wine label must include a standard drinks declaration (Standard 2.7.1). A standard drink is the amount of wine containing 10 grams of ethanol measured at 20° C. If the product contains: • less than 10 standard drinks, the statement of the number of standard drinks must be accurate to 1 decimal place • more than 10 standard drinks then the statement of the number of standard drinks must be accurate to the nearest whole number The form of the standard drink statement is: “contains approx. x.x standard drinks”. The word ‘approximately’ may be spelt in full if desired.

Standard drinks can be calculated on the labelled alcoholic content of the wine.. The formula for calculating the number of standard drinks is: 0.789 x the alcohol content x the volume of the container (in litres).

So for a wine with an actual alcohol content of 12% in a 750 ml bottle the formula is: 0.789 x 12 x 0.75 = 7.1.

Lot identification A wine label must include lot identification on the label or bottle (Standard 1.2.2). However, if there is just one bottling run for a particular wine then there is no need to include a lot number, as the lot’s identification is self-defined.

OPTIONAL INFORMATION There are very few restrictions on the information that you can use on the label of a bottle of wine. Wine labels cannot: • bear health claims; • make representations as to being low in alcohol or nonintoxicating; or • be false or liable to mislead or deceive consumers.

The Advertising Standards Authority’s “Code for Advertising and Promotion of Alcohol” and the Fair Trading Act provide further guidance in this regard.

All information on a wine label (as well as any other material used to present or describe a wine) is subject to the Fair Trading Act 1986, which prohibits misleading or deceptive conduct in trade, conduct that is liable to mislead in respect of goods, and false or misleading representations as to the quality, grade composition, style or nature of products. The Bell Gully Winegrowers Legal Handbook provides useful guidance in relation to the Fair Trading Act. Note that misleading or

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deceptive conduct or representations relating to goods supplied from New Zealand to China will be an offence under the Fair Trading Act and may authorise a search warrant being issued in New Zealand.

Grape variety, vintage and geographical indication From vintage 2007, the following rules for label claims covering grape variety, vintage and the area where the grapes were grown (other than the country of origin) apply: • single variety, vintage or area: at least 85% from the stated variety, vintage or area. For example, if a label says the wine is ‘2007’, at least 85% of that wine must be from the 2007 vintage • blends: at least 85% of the blend must be from the stated varieties, vintages or areas. For example, if the wine label says ‘Chardonnay Chenin Blanc, then at least 85% of that wine must have been made from Chardonnay and Chenin Blanc grapes • combination claims: the combination referred to must be at least 85% of that wine. For example, if a label states that the wine is a ‘2008 Marlborough Pinot Noir’, then 85% of the wine must be from Pinot Noir grapes grown in Marlborough in the 2008 vintage • where a label refers to more than one grape variety, more than one vintage, or more than one area, these must be presented in descending order of proportion in the blend.

Using the ‘Chardonnay Chenin Blanc’ example above, as well needing to meet the 85% rule, there must be a greater proportion of Chardonnay than Chenin Blanc in the blend • A label must not include a claim about grape variety, vintage or area of origin if that wine contains a greater percentage of wine from another grape variety, vintage or area of origin that is not referred to by that label. For example, a wine that contains 75% Cabernet Sauvignon, 15% Pinotage and 10% Merlot could be referred to as a ‘Cabernet Pinotage’ or a ‘Cabernet Pinotage Merlot’ but not a ‘Cabernet Merlot’ • Cultures of micro-organisms used to make wine may be excluded from the minimum content calculations (up to a maximum of 50ml/L) as can brandy or other spirit used for fortifying wine • The use of concentrated grape juice as a sweetener is excluded from the 85% region, variety, vintage calculations.

This exclusion does not apply to the country of origin statement • An exemption applies to wines made from or containing wine from the 2006 vintage. Contact NZW if you require further information Cabernet MPI has advised that: • it is acceptable to use “Cabernet” as a synonym for Cabernet Sauvignon but not for Cabernet Franc or a combination of those two varieties • if Cabernet Franc is part of a wine label claim about grape varieties, it must be named in full

Sauvignon Gris “Sauvignon Gris” is a statement regarding a single grape variety (not a blend of Sauvignon Blanc and Pinot Gris). The 85% rule therefore applies so that if a wine is labelled “Sauvignon Gris”, then at least 85% of that wine must have been made from Sauvignon Gris grapes.

• the wine must be made from 100% accredited vineyard grapes • the wine must be wholly produced in accredited winery facilities • the SWNZ logo rules are fully complied with For further information please contact karen@swnz.org.nz.

Moscato

Health advisory information

MPI has advised that “Moscato” (or “Muscato”) is a varietal descriptor and can therefore only be used where at least 85% of the wine consists of “Muscat” varieties. If any further differentiation of the Moscato variety is given (e.g. Muscat of Alexandria), then at least 85% of that wine must have been made from the named variety.

Wineries are encouraged to promote safe and responsible consumption on their wine labels. Pregnancy health advisory labels are particularly encouraged, such as written messages indicating that the safest option for pregnant women is not to drink while pregnant or the pregnancy advisory logo.

Single vineyard statements Some wine labels bear statements that create the impression that the wine is made from grapes are exclusively grown in a specific vineyard (e.g. “single vineyard” followed by a vineyard name). Where such terms are used, NZW’s view is that the grapes should be exclusively sourced from the named vineyard in order to avoid creating a misleading impression.

Exports The 85% rule is now a benchmark minimum content for all New Zealand wine, whether sold domestically or exported. This means that, in principle, all wine made from 2007 onwards and exported from New Zealand must be made in accordance with the 85% rule above, subject to the following: • if the overseas market has a stricter labelling requirement, the overseas market requirement must be complied with.

• if the overseas market has a less strict requirement and MPI has given specific permission for exporters to use the less strict requirement applying in that market, then the less strict requirement is available to exporters.

Environmental, sustainability and organic claims The Commerce Commission requires that “Businesses making environmental claims - including statements about sustainability, recycling, carbon neutrality, energy efficiency, use of natural products or impact on animals and the natural environment should ensure those claims are accurate, scientifically sound and substantiated.” New Zealand Winegrowers recommendation is that all such claims should be substantiated by current full certification to an appropriate third party scheme.

New Zealand Winegrowers provides detailed guidance on the use of environmental, sustainability and organic claims in the New Zealand Winegrowers Code of Practice for Environmental Claims available at www.nzwine.com.

In order to use the Sustainable Winegrowing New Zealand (SWNZ) logo, permission must be granted by the SWNZ National Coordinator. Permission is only granted under the following circumstances and is at the discretion of SWNZ:

Wineries are also encouraged to use the Cheers! logo as a way of driving consumers towards the www.cheers.org.nz website where useful information on safe and responsible drinking can be found. To obtain a copy of the logo and conditions of use, contact New Zealand Winegrowers.

Ice wine New Zealand is a signatory to the World Wine Trade Group Agreement on Requirements for Labelling, which contains provisions regarding the use of the term “Ice Wine” / “Icewine”.

The Labelling Agreement defines “Ice Wine” / “Icewine” as a product made from grapes that have been naturally frozen on the vine. Once the agreement is fully implemented, only wines that comply with this definition will be permitted for export to USA, Australia, Canada, Chile and Argentina. However, wines that do not comply with this definition (i.e. wines made from grapes or wine that have been artificially refrigerated) may continue to be sold in New Zealand.

The USA already has rules in place dealing with “Ice Wine” / “Icewine” pursuant to which it will not permit use of the term “Ice Wine” / “Icewine” for wines made from grapes or wine that have been artificially refrigerated. However, it will permit use of the term “Ice” for such wines as part of a brand – e.g. “Freddy’s Ice”.

The Labelling Agreement does not apply to exports to nonsignatory countries. However, some non-signatory countries have their own rules regarding the use of “Ice Wine” / “Icewine”, including China and the European Union.

Batch consistency Good winemaking practice suggests that where a wine has been produced and bottled in a number of batches, those batches should be consistent in terms of organoleptic characteristics and chemical profile (allowing for testing tolerances and the effects of maturation). Where batches of wine are produced that are not representative of other wine sold under the same label in a single market, we recommend that these be distinguished through their labelling. For example, early batches of wine for immediate release could be labelled as “Early Release”, “First Release” or similar.

• the wine company registered with NZW must be a SWNZ Tier 3 member

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WHAT ELSE YOU SHOULD KNOW Cleanskins Wines sold as “cleanskins” still need to comply with labelling regulations when they are sold at retail or in the on trade.

If cleanskin wines are sold at wholesale, they must still bear the product name (e.g. “wine”, “Cabernet Sauvignon”, “Port”), lot identification and name and address of the supplier on the bottle or carton. Further information on mandatory labelling requirements must be provided to the wholesale purchaser on request.

Cartons Outer packaging does not need to be labelled or marked if it is: • for the purposes of transportation and distribution only; and • of a kind intended to be removed before the food is offered for retail sale; and

It is vital that before printing your labels that you check that your barcode scans easily. A ‘pass’ on the international standard for barcode quality – a ‘verification test’ - is often a trade requirement. For further information and assistance contact GS1 New Zealand at www.gs1nz.org or 04-494 1050.

Wines over 15% alcohol There is no legal maximum alcohol limit for table wine or fortified wine in New Zealand. However, fortified wine over 15% alcohol may not be sold in a supermarket, but may be sold in other offlicensed premises.

Note: Excise is payable at the higher fortified wine rate if a wine is over 14% alcohol and has been fortified with spirits. However, if a table (i.e. unfortified) wine is over 14% alcohol it does not qualify for the higher excise rate. It is the addition of fortifying spirit, rather than the alcohol level, that makes a wine qualify for the higher excise rate.

• customarily not taken away by the purchaser of the food However, if you intend to sell wine at retail by the case, then: • each bottle should be properly labelled; and • the outer carton should bear the product name (e.g. wine, Chardonnay, etc) together with either the number of the bottles contained in the outer package and the quantity of each of those bottles (e.g. 12 x 750ml) or the total quantity (e.g. 9 litres) If you are selling unlabelled cleanskins at wholesale, you need to mark the carton as set out above.

Note: These guidelines apply to New Zealand only. Different countries’ retailers or importers (e.g. Canada’s LCBO Product Packaging Standards) may have their own requirements.

Barcodes There is no legal requirement to include a barcode on your label.

Barcodes are usually required by retailers.

A barcode is essentially a method for encoding in machinereadable format a unique number for a product which is called a Global Trade Item Number (GTIN).

The EAN-13 barcode (encoding a 13 digit GTIN) is the barcode used in New Zealand, Australia, Asia and Europe and is generally acceptable worldwide for all retail/consumer items (e.g. individual bottles of wine, cartons of wine to be sold by the case). However, for historical reasons, the USA and Canada have used a 12-digit GTIN encoded into a barcode called a UPC-A. Most retailers in North America after 1 January 2005 should accept EAN-13 barcodes, but some still require a UPC-A. Some retailers and wholesalers require special barcodes on cases and pallets of wine, either for automated scanning on conveyor belts (an ITF-14 barcode encoding a 14-digit GTIN) or for traceability purposes (an EAN-128 barcode that can encode details such as batch, processing date, Global Location Number of the vineyard etc).

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AUSTRALIA

Australian labelling laws The Australia New Zealand Food Standards Code (Code) applies to both Australia and New Zealand. New Zealand wines labelled in accordance with the Code will comply for the Australian market as regards mandatory information. The effect of the Trans Tasman Mutual Recognition Arrangement (TTMRA) and the Australia New Zealand Closer Economic Relations Trade Agreement (ANZCERTA) also means that, in general, a wine that can be legally sold in New Zealand can also be sold in Australia.

Mandatory information A label designed in compliance with New Zealand labelling laws can also be used for wines exported to Australia.

Optional information Again, the situation is generally the same as applies in New Zealand, although there are two areas where care is needed: Vintage, variety and geographic indication While the effect of the Trans Tasman Mutual Recognition Arrangement technically means that Australia’s minimum content requirements for vintage, variety and geographic indication do not apply to New Zealand wines, it would be prudent to be guided by the Australian requirements when exporting to that country. The requirements are as follows: • vintage: an 85% minimum content requirement applies • where only one variety is used on a label: an 85% minimum content requirement applies

The following 11 names can no longer be used in Australia (unless the wine originated in that GI and conforms with any applicable conditions): Champagne (including Methode Champenoise), Burgundy, Chablis, Claret, Graves, Marsala, Moselle, Oloroso, Port, Sauternes, Sherry, or White Burgundy. The names Hermitage and Lambrusco are also protected from 1 September 2011.

Wholesalers/retails can, however, exhaust existing stocks after that date.

Exporters should also take note of the following advice from the Australian Wine and Brandy Corporation in relation to using protection names to describe a wine: Please note that it is illegal to use protected names [other than in compliance with the prescribed conditions] in the description and presentation of wine in any context whatsoever, even in an otherwise true statement in textual form on a back label (eg. ‘this wine is made from a typical Bordeaux blend of grapes’, or ‘Marsanne is a native variety of the Rhone Valley’, or ‘my family have grown grapes in Chianti for generations’, or ‘this wine is from vineyards near the famous Barossa Valley’ or ‘this wine is equal to a top Hunter Semillon’). Protected Names are only protected when describing a wine, but it is difficult to say that anything on a wine label is not describing that wine. Note that country names are also protected. To clarify the boundaries for use of Protected Names, you could, in say promotional material use Protected Names to describe family history, or discuss generally the wine styles you make, or comparing your climate conditions with European regions etc but whenever you are describing a particular wine then Protected Names cannot be used in any context.

• where up to three varieties are named, these must be presented in descending order of proportion • where three to five varieties are named, the wine must comprise 100% from the named varieties (excluding up to 5% for the incorporation of additives). The varieties must be presented in descending order of proportion • where one geographical indication is used, the minimum content is 85% • where up to 3 geographical indications are used, these must be presented in descending order of proportion Protected Geographical Indications (GI) The Australian provisions on the protection of certain European and Australian geographical indications are excluded from the mutual recognition arrangements between Australia and New Zealand. This means that New Zealand producers may not use any registered protected names on their wine labels unless they comply with the conditions attached to those names.

The Register of Protected Geographical Indications and Other Terms lists Australia’s protected geographical indications and conditions of use applicable to those indications2.

2

Please note that the rules for Traditional Expressions do not apply to imported wine.

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EUROPEAN UNION (EU)

EU labelling laws

Sweet and high alcohol wines

All Member States of the European Union share the same general labelling laws. In some cases, different authorities in various countries will have different interpretations of those laws, or additional national requirements.

A wine will qualify as “normal” wine if it meets the following criteria:

The main laws are Regulation 1234 of 2007 (the core EU wine law) and Regulation 607 of 2009 (the wine labelling law). There are a number of other laws that touch on aspects of labelling, such as fair trading, allergen declarations and organics.

Note that these rules deal specifically with the requirement for a 750ml bottle of still wine. Other types of wines (e.g. sparkling, fortified) may be subject to a different set of rules that are not covered here. If you would like assistance with labelling for such wines, please contact us.

Mandatory information Presentation and placement All compulsory statements must be easily readable, in indelible characters large enough to stand out against the ground on which they are printed and clearly distinguishable from all other content of the labelling.

The following information must appear in a single field of vision clearly distinguishable from all other content and printed horizontally: • category of grapevine product (i.e. product name) • country of origin (what the EU calls “indication of provenance”) • importer • net contents; and

• 8.5% or more actual alcohol • up to 20% total (i.e. actual + potential) alcohol • no enrichment (including chaptalisation) • no sweetening or sugar adjustment Outside those parameters, the wine will need to come within one of the following special categories: “wine of overripe grapes” or “wine of raisined grapes” and be labelled as such. The definitions are as follows: Wine from overripe grapes: • is produced without enrichment • has a natural alcoholic strength of more than 15% vol • has a total alcoholic strength of no less than 15 % vol. and an actual alcoholic strength of not less than 12% vol Wine from raisined grapes: • is produced without enrichment, from grapes left in the sun or shade for partial dehydration • has a natural alcoholic strength of at least 16% vol (or 272 grams sugar / litre) • has a total alcoholic strength of at least 16 % vol. and an actual alcoholic strength of at least 9% vol We recommend that all wines with more than 15% total alcohol use one of these designations on the label to avoid problems in the market.

• alcohol declaration If a geographic indication is used, this must also appear in the same field of vision.

You can repeat mandatory information in other places on the label.

Product name All imported wine labels must bear the “category of grapevine product” (i.e. product name): • for still, unfortified wines of less than 15% total alcohol, the category of grapevine product will simply be “wine” • fortified wines must use the designation “liqueur wine” and wines over 15% total alcohol must use the designation “wine of overripe grapes” or ”wine of raisined grapes” • sparkling wines may use the categories: sparkling wine, quality sparkling wine, quality aromatic sparkling wine, aerated sparkling wine, semi-sparkling wine or aerated semisparkling wine In every case, wines must comply with the definition that applies to each category (see Annex 4 for more information).

The category of grapevine product must appear in the same field of vision as the country of origin, the importer details, the net contents, and the alcohol declaration.

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Country of origin All imported wines must bear an “indication of provenance” on the label. For New Zealand wine, the indication of provenance will be “New Zealand”.

The category of grapevine product can appear together with the indication of provenance as “New Zealand Wine” (recommended) or “Wine of New Zealand”. Alternatively it can appear as ”Product of New Zealand”, “Produced in New Zealand” or equivalent expressions.

The indication of provenance must appear in the same field of vision as the category of grapevine product, the importer details, the net contents, and the alcohol declaration.

Alcohol by volume All imported wine labels must bear a statement of alcoholic content. This must be expressed as x% vol. in whole or half units (e.g. 12% vol., 12.5% vol.) It may be preceded by the words “actual alcoholic strength”, “actual alcohol” or “alc”. The minimum print size is 3mm for a 750ml bottle. The tolerance for the alcohol statement is +/- 0.5%.

The alcohol statement must appear in the same field of vision as the category of grapevine product, the importer details, the net contents, and the country of origin.

Net contents All imported wine labels must bear the net contents. This must be expressed in litres, centilitres or millilitres, and must be at least 4mm in height when appearing on a 750ml bottle.

The net contents must appear in the same field of vision as the category of grapevine product, the country of origin, importer details, and the alcohol declaration.

Importer All imported wine labels must bear the name of the importer, together with the local administrative area and Member State in which their Head Office is located. These details must be preceded by the words “importer” or “imported by”. ‘”Importer” is defined as: a natural or legal person or group of such persons established within the Community assuming responsibility for bringing into circulation non-Community goods. If the same wine enters the EU market (i.e. is released from bond) in more than one country, the importer in each country may need to be included on the label.

The importer details must appear in the same field of vision as the product name, the country of origin, net contents, and the alcohol declaration.

Sulphite declaration All imported wines must bear a sulphite declaration if they contain more than 10 mg/l of sulphur dioxide. The form of the declaration is contains sulphites or contains sulphur dioxide in the approved language of the market in which the wine is sold.

American spellings (“sulfites”, “sulphur”) are permitted. The declaration can appear on any label.

Many EU Member States require that the sulphite declaration is in the national language or languages. This will present difficulties for wineries exporting to multiple EU markets, as it may be necessary to have different sulphite declarations for each market. A list of the relevant languages is attached at Appendix 3B.

• they contain traces of milk or egg products (see below for further information); and • they are labelled in New Zealand on or after 1 July 2012 (or in the case of bulk wine, they have entered the EU market after that date) As noted above, it is only necessary to label wines if they contain traces of milk or egg products. The EU has specified that methods of detection recommended by the International Vine and Wine Organisation (OIV) may be used. This requires an ELISA test kit that can test to the limit of detection of 0.25 mg/L. You should contact your laboratory for further information.

The declaration can appear on any label. The form of the declaration is “contains milk” or “contains egg” in the approved language of the market in which the wine is sold. If multiple allergens are present (including sulphites) you do not need to repeat the word “contains”. Lists of the relevant languages, permitted wording and translations are attached at Appendix 3.

You can also choose to use one of the official pictograms in Annex 3D. This is optional but tif you choose to use them they must still be accompanied with the “contains milk/egg” statements. Allergen declarations for fish products are not required in the EU. Lot identification All imported wine labels must bear a lot number on a label or on the bottle. This should appear as “L” followed by an alphanumeric code (e.g. “L1234” or “L123AB”).

Health advisory (France only) French law requires all wine to bear the following health message and/or pictogram: « La consommation de boissons alcoolisées pendant la grossesse, même en faible quantité, peut avoir des conséquences graves sur la santé de l’enfant. »

The following pictogram may be used on the label in addition to the written form of the sulphite declaration. However, it is not compulsory.

The text of the message means: “The consumption of alcoholic beverages during pregnancy, even in small quantities, can have serious effects on the health of the child.”

The health message should be written in contrasting type, so as to be visible, readable, clearly comprehensible, and indelible.

It must not be obscured or interrupted by other indications or images. It does not need to be in any particular colour or size.

Allergen declaration Labels for wines exported to the EU must include an allergen declaration if: • they are produced from grapes grown in the 2012 vintage or subsequent vintages; and

The health message must appear in the same field of vision as the alcohol declaration. This has implications for how labels are designed for multiple markets that include France. If you wish to avoid having to put the health message on your front label, you will need to place all of your “single field of vision” information (which includes the alcohol declaration) on the back label. You

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may still repeat the “single field of vision” information on the front label if desired.

The UK has confirmed that this warning/pictogram is acceptable in their market, but we have not received such confirmation from other markets. We have received advice that the USTTB has indicated that the French warning/pictogram is not acceptable in the USA.

Optional information Geographical indication The geographical indications permitted for use in the EU are set out in Annex 2. To use a geographic indication, the wine must be at least 85% from the stated region. No more than one geographical indication may be used on a label. However, the names of smaller or larger geographical units and geographical area references may also be used (e.g. Bannockburn, Central Otago) provided that: • at least 85% of the wine is sourced from the specified geographical unit/area (e.g. Bendigo); and • the remaining 15% comes from the geographical indication (e.g. Central Otago).

Variety A grape variety may be used on the label of a wine exported to the EU. Only varieties that are on the list of approved varieties submitted to the OIV may be used. All vinifera grape varieties grown in New Zealand that we are aware of are currently on the list. However, if you are developing a new variety, we recommend that you check with us whether the variety is listed or not.

New rules appear to prevent or limit New Zealand producers using some Italian grape variety names including: Barbera, Freisa, Montepulciano, Nebbiolo, Primitivo, Sangiovese, Verdicchio and Vernaccia. Appropriate synonyms may be used.

The minimum content for a single grape variety is 85%. Two or more varieties may be used on a label. The wine must be derived 100% from the stated varieties and they must be presented in descending order of proportion in letters of the same height.

Where a single grape variety appears in conjunction with a vintage, then the 85% rule applies concurrently (e.g. if a wine label says 2004 Cabernet Sauvignon, then it must contain at least 85% 2004 Cabernet Sauvignon).

Note that the Wine Standards Board in the UK has expressed the view that the grape variety name must be clearly distinguishable from other information, meaning that vintage dates of brand names may not be permitted on the same line close to the variety name.

Vintage A vintage date may be used on the label of a wine that bears a geographical indication. The minimum content for a vintage date is 85%. Where a single grape variety appears in conjunction with a vintage, then the 85% rule applies concurrently (e.g. if a wine label says 2004 Cabernet Sauvignon, then it must contain at least 85% 2004 Cabernet Sauvignon).

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Traditional terms “Traditional terms” are terms that the EU considers should be used exclusively with EU protected geographical indications.

Exporters should be aware that a number of “traditional terms” are now protected in the EU in their specified language. Key “traditional terms” of relevance to New Zealand exporters (protected in the bracketed languages) include: Auslese (Ger); Cream (En) Premium (Cz) Vendages Tardives (Fr) Chateau (Fr) Domaine (Fr) Reserve (Ger) Tawny (En) Clos (Fr) Fine (It)

Spatlese (Ger) Villages (Fr) Classic (Ger) Noble (Sp) Superior (Por, Sp) Vintage (En) Claret (Fr) Ruby (En) Sur Lie (Fr)

Note that Ruby, Tawny and Vintage are only protected in relation to fortified wines.

Traditional terms are only protected in the language and for the categories of grapevine products specified in the regulation. This is generally taken to mean that “Reserve” is only protected when used on a wine label in the German language. However, if the use of such a term on an NZ wine label could be confused with its use as an EU traditional term then that could also potentially create a problem. Enforcement of the rules is at the discretion of the Member States in which potentially infringing product is sold.

Production methods References to production methods are generally permitted.

However, certain references, including “bottle fermented”, references to oak aging and “rosé” are subject to special rules.

Bottle fermented/ traditional method Specific rules apply to the use of the term “bottled fermented”, including a requirement that the wine undergoes secondary fermentation in a bottle of at least 90 days. More stringent rules apply to wines described as “traditional method”, “méthode traditionnelle”, “classical method”, “crémant” etc. See Annex 4 to this guide for more information.

Oak aging The following terms are currently the only terms permitted to describe wine that has been fermented, matured or aged in a wood container.

BARREL

BARREL MATURED

BARREL AGED

[…]-cask fermented

[…]-cask matured

[…]-cask aged

[indicate the type of

[indicate the type of

[indicate the type of

wood]

wood]

wood]

CASK FERMENTED

CASK MATURED

CASK AGED

FERMENTED

These terms may only be used in relation to a wine that bears a geographical indication. Reference to wood containers is not permitted to describe a wine produced using oak chips, even when that wine is subsequently fermented, matured or aged in a wooden container.

Rosé Under EU rules, red wine may not be added to white wine to produce a “rosé”. However, OIV rules (which can be followed by NZ producers as an alternative to EU rules) permit blending of different wines without any limitation on production of rosé wine.

Both EU and OIV rules permit blending of white wine into a red wine to produce a red wine (e.g. Syrah/Viognier).

Our interpretation is that NZ producers can continue to produce wines blended from red and white varieties. However, it is not clear whether these wines can be called “rosé”.

Rosé wines produced from red grapes (e.g. by the saignée method) can be labelled “Rosé”. Addition of red wine to white wine for the production of sparkling rosé wine is permitted.

association representing industry) made a pledge to Government to proactively encourage all producers to show clear unit labelling, the recommended daily limits and a warning about drinking when pregnant. In the face of a strong Government push for mandatory warning labelling, the scheme has been developed in conjunction with the UK Department of Health.

Depending on the uptake of the voluntary scheme, the Government will decide whether to proceed with a mandatory approach. The format is as follows: You can also access the Portman Group’s guidelines on the labelling scheme here. Under the scheme it is anticipated that 80% of all alcoholic beverages in the UK will carry this messaging by 2013. For more information on the scheme see wsta.co.uk

Sweetness levels Sparkling wines must bear an indication of sugar content (e.g. brut, sec etc). See Annex 4 to this guide for more information.

For other wines, an indication of sweetness is optional but if it is used the wine must fall within the appropriate sweetness range as below.

Dry, sec, etc.

If its sugar content does not exceed: 4 grams per litre, or 9 grams per litre, provided that the total acidity expressed as grams of tartaric acid per litre is not more than 2 grams below the residual sugar content.

Medium dry, demi-sec etc

If its sugar content exceeds the maximum set at above but not exceeds: 12 grams per litre, or 18 grams per litre, provided that the total acidity expressed as grams of tartaric acid per litre is not more than 10 grams below the residual sugar content.

Medium, medium sweet, moelleux etc.

If its sugar content is higher than the maximum set at above but not more than 45 grams per litre.

Sweet, doux, dolce etc.

If its sugar content is of at least 45 grams per litre.

The “e” mark The “e” mark is a symbol that may be used alongside the net contents to signify that a bottle has been filled according to the average quantity system and is backed up by some sort of verification process. It is not a mandatory requirement.

Organic claims The European Union has recently introduced a new standard for organic winemaking. Previously, the EU only recognised organic viticulture, so qualifying products had to be labelled “wine made from organically grown grapes”. The intent of the new standard is to recognise organic winemaking as well as organic viticulture. In the future, wine produced in accordance with the EU rules and certified under procedures recognised by the EU as having equivalence will be able to carry the EU organic logo. Until equivalence between the EU standard and New Zealand’s standards is achieved, qualifying product labelled after 31 July 2012 may continue to bear the previous designation of “wine made from organically grown grapes.” For additional information on the equivalence process, please contact MPI or Organic Winegrowers New Zealand.

Health advisory The NZ standard drinks declaration should not appear on an EU wine label. It is not a legal requirement and many EU member states calculate standard drinks of alcohol units differently.

In March 2011 the UK’s Portman Group (a social responsibility

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The Green Dot The Green Dot (“Grüne punkt”) signals a company’s compliance with a German law that makes the recycling of packaging material mandatory. By paying a form of licence fee, a company is authorised to use the Green Dot on its packages, and is thus exempt from the statutory requirement to recycle the packaging.

The requirements to comply with the law are imposed on parties within Germany – in the case of imported product this means the importer. It is therefore up to your importer to determine whether the Green Dot is necessary on your labels.

Other information Wine labels may include other material not covered above, provided that there is no risk that such material might be misleading, particularly by creating confusion with the compulsory or optional items discussed above.

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UNITED STATES OF AMERICA

United States labelling laws The USA labelling regulations are contained in the Code of Federal Regulations, Title 27, Part 4. These regulations are administered by the US Alcohol and Tobacco Tax and Trade Bureau (USTTB),a division of the Department of Treasury. The grouping of alcohol alongside tobacco reflects the history of alcohol issues in the United States, and the level of regulatory control that is the legacy of prohibition.

All wines sold in the USA must first obtain a Certificate of Label Approval (COLA) from the USTTB. This can be applied for online at ttbonline.gov Mandatory information Presentation and placement All mandatory information must be legible and on a contrasting background. In many cases, specific type size and placement will be specified. If any of the mandatory information is contained among other descriptive information, then it should be of a size substantially more conspicuous than the descriptive information.

The brand name, class or type designation and alcohol declaration must be placed together. The label on which these are presented is designated the “brand label”. If these items appear on more than one label, the winery can choose which label to identify as the “brand label” when applying for a COLA. It is permitted to repeat mandatory information in other places on the label.

Country of origin All imported wine labels must bear a country of origin statement.

This may appear on any label. TTB guidelines indicate that “Product of New Zealand” is the preferred form. However, the TTB has now indicated that it will accept “New Zealand Wine” or “Wine of New Zealand”.

Alcohol by volume All wines over 14% alcohol must bear a statement of alcoholic content. Wines of between 7% and 14% alcohol may either bear a statement of alcoholic content or use the type designation “table wine” or “light wine” (see below). The latter option is not desirable in most cases, however, since it effectively precludes the use of a grape variety on the label.

The alcohol statement must appear on the brand label in lettering of between 1mm and 3mm in height, and may not be set off with a border or emphasized in any way. The following forms of alcohol statement are acceptable: “Alcohol (Alc.) xx% by volume (vol.)” or “xx% alcohol (alc.) by volume (vol.)” or “Alc. xx% vol. The third version can also be used in the EU. Full stops must be used for the abbreviated version.

Tolerance from the actual alcohol content is +/-1.5% for wines 7-14%. There is a tax boundary at 14%, and the declared content may not be in a different tax category from the actual content.

Over 14% the permitted tolerance is 1% between the declared and actual alcohol.

Net contents

Product Name All wine labels must bear a “class and type designation”. This can either be a generic description (e.g. “white wine”, “sparkling wine”,3 “Port”) or a varietal statement.

If you have more than one item on a label that could be a class or type designation, the USTTB will use the most specific item as the class and type designation (e.g. if you have both “Chardonnay” and “white wine” on a label, “Chardonnay” becomes the class and type designation and must therefore appear on the brand label). In most cases, therefore, the varietal statement will need to appear on the brand label. It must be in letters of at least 2mm in height for a 750ml bottle.

Note: you can only use a variety name as the class and type designation if your wine label also has an “appellation of origin” in accordance with the conditions below. This means that if you have a variety on the label, you must also have a geographical indication.

The minimum content for a single grape variety is 75%. The USA Overseas Market Access Requirements allow for this variation from the 85% standard. Multiple varieties may be used. In that case, all varieties must be stated, with the percentage of each variety in the blend also stated (e.g. “Cabernet Sauvignon 75%, Merlot 25%”). When the percentages are stated with the varieties on the brand label, they do not need to be repeated if the varieties are themselves repeated elsewhere on the label.

All wine must bear an indication of net contents. This may appear on any label, and must be expressed in millilitres for a 750ml bottle.

Importer All imported wine labels must bear the name and address of the importer. The form is: “Imported by [name of importer] [address of principal place of business].” This may appear on any label and must be in lettering of at least 2mm in height for a 750ml bottle. If the wine is bottled or packaged in the USA, different rules apply.

“Importer” means either the holder of an importer’s basic permit making the original Customs entry into the United States or for whom such entry is made; or the holder of an importer’s basic permit who is the agent, distributor, or franchise holder for the particular brand of imported alcoholic beverages and who places the order abroad. The name should be that which appears on the importer’s basic permit. The address should be the city and state shown on the importer’s basic permit.

Brand name All wine labels must bear a brand name. If it does not bear one, the name of the bottler, packer or importer becomes the brand name. The brand name must appear in “the usual distinctive design”. It must not convey an erroneous impression as to age, origin, identity or other characteristics of the wine. The brand name must be at least 2mm in height for a 750ml bottle. This must appear on the same label as the class and type designation and the alcohol declaration.

3 If you are labelling a sparkling wine, please see Annex 4 for the relevant definitions.

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Sulphite declaration

Geographical indication

All wines containing more than 10ppm sulphur dioxide must bear a sulphite declaration. This may appear on any label and must be in lettering of at least 2mm in height for a 750ml bottle. The required form is: “Contains Sulfites” (note the US spelling) or “Contains Sulphites”.

If you are exporting your wine to the USA, you must have a geographical indication on the label if you want to use a vintage date.

Health advisory All wine labels must bear a government alcohol warning. This must be at least 2 mm in height for a 750ml bottle, and must be in the following form: GOVERNMENT WARNING: (1) According to the Surgeon General, women should not drink alcoholic beverages during pregnancy because of the risk of birth defects. (2) Consumption of alcoholic beverages impairs your ability to drive a car or operate machinery, and may cause health problems.

The first two words must be in bold and in capitals. The remainder of the statement must appear as a continuous paragraph and may not appear in bold. The number of type characters may not exceed 25 per inch for 2mm minimum type size.

The NZ standard drinks declaration should not appear on a US wine label. It is not a legal requirement and the US calculates differently from NZ. Similarly, health advisory information other than the Surgeon general’s Warning should not appear on a US label.

Your geographical indication (called “appellation of origin”) must be a name that is listed with the USTTB as a New Zealand appellation of origin. These names are listed in Annex 1. The minimum content of wine from the stated appellation of origin is 85%.

USA rules do not permit the use of two separate geographical indications on a wine label (e.g. Marlborough/Gisborne).

However, if you want to use the name of a sub-region in conjunction with the name of a region (e.g. Awatere Valley, Marlborough) this is permitted provided that both names appear on the list in Annex 1.

If you are using a grape variety as your class & type designation (which will usually be the case for a varietal wine), the appellation of origin must appear on the same label and in the same field of vision, and in lettering substantially as conspicuous, as the class and type designation.

Producer The name and address of the producer can be used on the label, in addition to the importer’s details. If used, the name and address must be accompanied by an appropriate explanatory phrase identifying the specific winemaking operation (e.g.

“Produced by…”).

Optional information

Estate bottled

Vintage

The term “estate bottled” can only be used if 100% of the wine came from grapes grown on land owned or controlled by the winery, which must be located in the viticultural area that appears on the label. The producer must crush and ferment the grapes, finish, age and bottle the wine at the same winery in the stated viticultural area.

A vintage date can only be used if the wine also has a geographical indication (called “appellation of origin”). Until 13 September 2012, the requirement to include an appellation of origin when using a vintage date excluded the ability to use a country name – e.g. New Zealand - as a geographical indicator.

This has now changed and country names can now be used as a geographical indicator when including a vintage date.

Our interpretation of the rules for use of a vintage date is that: • New Zealand wines labelled with a geographical indication that coincides with a NZ political unit must have at least 85% wine from the stated vintage in order to use the vintage date on the label. At present all regions listed in Annex 1 fall within this category, with the exception of Waipara Valley • New Zealand wines labelled with a geographical indication that has been recognised and defined as a grapegrowing region at a Government level must have at least 95% wine from the stated vintage in order to use the vintage date on the label. Currently, Waipara Valley is the only region that complies with this requirement, having been recognized and defined as a grape growing region by the Hurunui District Council

Allergen declaration Allergen declarations are currently not mandatory on the labels of wine sold in the USA. However, where an allergen declaration is used, all allergens used in the production of the wine must be declared in the following way: “Contains” followed by a colon and the name of the food source from which each major food allergen is derived, e.g. “Contains: milk and egg.”

Other information Labels may contain additional information provided that it does not conflict with or contradict mandatory information.

Additional information must be truthful, accurate, specific and not disparaging of competitors’ products, false or misleading.

Organic claims The Department of Agriculture has stringent guidelines for organic labelling. The USDA accepts the MPI’s programme for recognition of organic certifying bodies. As such, organic products certified by an MPI recognised Third Party Agency (TPA) to the USDA National Organic Standards, are permitted entry into the US. At present these certifying bodies are BioGro and AsureQuality. For more information on the organic labelling framework see the USDA’s Guidelines.

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Ice wine The USA has rules in place regarding use of the term “Ice Wine” / “Icewine”. The USTTB will not permit use of the term “Ice Wine” / “Icewine” for wines made from grapes or wine that have been artificially refrigerated. However, it will permit use of the term “Ice” for such wines as part of a brand – e.g. “Freddy’s Ice”.

Prohibited information There is a fairly lengthy list of things that are prohibited on a US wine label, although most of it would not be relevant to the average New Zealand wine producer. Additional information must not be obscene or indecent; give the impression that a wine contains distilled spirits or has intoxicating qualities (!); give the impression it belongs to a different class and type (e.g. words such as “lively”); simulate any sort of Government stamp; make claims about curative or therapeutic effects etc. In addition, still wines are prohibited from using terms which allude to any sparkling characteristics (such as frizzante, crackling, tingly, bubbly or cremant.

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CANADA

Canadian labelling laws Canadian labelling requirements are found in the Consumer Packaging and Labelling Act and Regulations and the Canadian Food and Drugs Act and Regulations. A useful guide to their labelling regime can be found on the Canadian Food Inspection Agency alcoholic beverage site.

Mandatory information Presentation and placement Canadian law requires that all mandatory information (except net contents and alcohol content which are bilingual) be presented in both French and English. Both language versions must be on the same label in the same type. Certain information is supposed to be presented on the front label (although this is not always enforced) which means that the usual front label may not work for this market.

A minimum type size of 1.6mm in height based on the lowercase letter “o” is specified for most mandatory information. Other mandatory information must be easily read and clearly and prominently displayed, and the 1.6mm standard is recommended.

Product name All wine labels must bear the common name of the product in both French and English, e.g. “wine / vin”. This must appear on the front label, and must be in letters of at least 1.6mm in height based on the size of the lowercase “o” (even though there is no “o” in wine). It is also permissible to use an adjective (e.g. red wine/vin rouge).

Country of origin All wine labels must indicate the country of origin on the front label. This must be in English and French and should appear as either “Product of New Zealand – Produit de Nouvelle-Zélande” or “New Zealand Wine - Vin de Nouvelle-Zélande”. There is no minimum type size requirement, but the 1.6mm standard is recommended.

Alcohol by volume All wine labels must bear a declaration of alcoholic content on the front label. This can appear as either “x% alcohol by volume” or “x% alc./vol.” (full stops must be used in the abbreviated version). The abbreviated version is considered to be bilingual and therefore does not need to be repeated. The minimum type size is 1.6mm based on the lowercase “o”.

There is nothing specific in Canadian Federal law about tolerances for the alcohol declaration, although this may be covered by the general provisions in Canadian food labelling laws related to misleading labelling. We understand that, in practice, the provincial liquor boards in Ontario and Quebec currently operate a tolerance of +/- 0.5%.

Net contents All wine labels must bear a declaration of net contents. For quantities of less than 1 litre, this should be expressed in millilitres (e.g.750 ml). The acceptable symbols are ml, mL and mℓ.

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This should be placed on the front label and must be clearly and prominently displayed, easily legible and in distinct contrast to any other information on the label. The numerical portion of the net contents declaration must be in bold and in a type size that is proportionate to the area of the principal display surface of the container – the larger the container, the larger the text must be.

The “principal display surface” is the 40% of the surface of the bottle where the front label appears. The symbols used in the net contents declaration (i.e. “ml”) must be at least 1.6mm in height based on the lowercase “m”.

The net contents declaration should technically be in English and French, although “750 ml” would be considered to be bilingual and therefore does not have to be repeated.

Note: wine can only be sold in Canada in standardized container sizes – i.e. 50, 100, 200, 250, 375, 500, 750 millilitres and 1, 1.5, 2, 3 or 4 litres.

Producer / Importer All wine labels must bear the name and principal place of business of the person by whom or for whom the wine was produced. The business identity is the registered name of the company. The principal place of business should include the city or town and the country. This may appear anywhere on the label.

The minimum type size is 1.6mm based on the lowercase “o”. This must be shown in English and French.

If you are using the name of a Canadian agent to meet the producer name requirements, then you must say “Imported by/Importé par <Agent’s identity etc.>” or “Imported for/ Importé pour <Agent’s identity etc.>” or else use a geographical indication immediately adjacent to the Canadian agent’s details in type of the same size or larger. The preferred wording for wine to be sold in Quebec (via the SAQ) is “represented by / représenté par”.

Allergen declaration Canada’s allergen labelling regulations came into force on 4 August 2012. All non-vintage wines and wines with a vintage date of 2012 and later must meet the new allergen labelling requirements.

Sulphites Where a wine contains sulphite levels of 10mg/L or more the declaration will be required in English and French, and the specified form will be: “Contains sulphites / Contient des sulphites”. Any of the following common names will be accepted: “sulfites”, “sulfiting agents”, “sulphites” and “sulphiting agents.”

Eggs, Fish or Milk Products If an allergen is present due to the use of fining agents from eggs, fish, or milk, the allergen must be declared on the label (also in the “contains [allergen]” form) in both English and French. Because the Canadian legislation requires allergens to be declared only when present in the final product, allergen labelling will be required only if the fining process leaves behind some protein from the food allergen in the wine. While the

regulations do not provide a specific threshold level, typical test methods for food allergens can detect in the low parts per million (ppm) range and if these methods did not detect any protein from the food allergen in the wine, then it could be considered that no protein was present and no label statement is required.

Canadian industry has produced a guidance document on the labelling of fined wines which provides an example of the process which may be required to support a decision not to label.

The Winemaker should determine, on a case-by-case basis, whether residues are, or are likely to be, negligible in quantity (and thus in public health significance) and in technical effect in the wine that will be offered for sale. Supporting evidence to assist in making this evaluation might include: 1. The unit processes to which the product will be exposed after fining that will serve to reduce or eliminate residues of fining agents or their by-products from the wine (i.e., the filtration processes, blending steps, etc.); and/or 2. Data from analytical tests showing that the residue levels are at or below a level of 1 mg/L” Please contact New Zealand Winegrowers for a copy of the Canadian Industry Fining Guidelines.

Optional information Any information on wine labels must be true and not misleading or deceptive. This applies to statements of vintage, variety and origin.

There are also a range of specific conditions around using terms such as: fresh, natural, homemade, no preservatives, guaranteed, pure, genuine etc.

Geographical indications While Canada does not have any specific minimum content requirements for variety, vintage or geographical origin (other than country of origin) in its national legislation, the guidelines for Canadian Vintner’s Quality Alliance (VQA) wines are instructive: • single-varietal VQA wines, where the variety is indicated on the front label, not less than 85% of the wine shall be made from the named individual grape variety • dual-varietal VQA wines, where the varieties are indicated on the front label, not less than 95% of the wine shall be made from the two varieties named, with the second being not less than 15% of the total In every case, the declared varieties shall be listed on the principal display panel in descending order of quantity, in identical type and identically displayed.

Standard drinks The NZ standard drinks declaration should not appear on a Canadian wine label. It is not a legal requirement and Canada calculates differently from NZ.

Environmental, sustainability and organic claims The Canadian Organic Products Regulations place strict new requirements on wine bearing organic/biodynamic or sustainable claims. The Canadian Food Inspection Agency (CFIA) recently signalled their intention to switch to a more stringent policy of enforcement of these regulations. However, you should be aware that provincial Liquor Control Boards may adopt a stricter approach. We have been advised that any wine arriving at LCBO warehouses without compliant organic labelling will be corrected at the supplier’s expense. Please note that organic statements are required to appear in both French and English.

In summary, the Regulations provide that only wine certified to either the Canadian or USDA NOP standard can be sold or marketed as an organic product. Certificates or letters from the certifying agency must be submitted to the LCBO to support all organic or biodynamic claims.

Suppliers must be prepared to provide proof (preferably third party certification) of any claim involving sustainable agriculture, “green” practices, etc.

Liquor Control Boards Alcoholic beverages can only be sold in Canada through the provincial Liquor Control Boards. Many Liquor Control Boards have a process for vetting the labels of any products that they sell. Some Liquor Control Boards will also have additional labelling or packaging requirements, as well as carton labelling requirements.

The LCBO Lightweight Glass Standard will apply to all purchase orders issued after 1 January 2013. For further information on the standard and its requirements consult the LCBO’s letter of notification which is available on their website.

Barcode requirements may differ from other markets. For further information on general barcode requirements consult the Canadian Product Identification Standards. The key variations from the GTIN (to find out what the GTIN is, see the section on ‘Barcodes’ in the New Zealand part of this Guide) are noted in “Appendix B” of the document. The Liquor Control Board of Ontario (LCBO) has a separate packaging standard which can be accessed at www.lcbo.ca Where possible, we have incorporated any additional regional labelling requirements into this guide, however, if you would like further information on the operation or policies of any of the Canadian Liquor Boards, we suggest you access the following sites: British Columbia Liquor Distribution Branch (LDB) Here Liquor Control Board of Ontario (LCBO) Here Alberta Gaming and Liquor Commission Here Société des alcools du Québec (SAQ) Here Saskatchewan Liquor and Gaming Authority (SLGA) Here Manitoba Liquor Control Commission (MLCC) Here Nova Scotia Liquor Corporation (NSLC) Here Newfoundland Labrador Liquor Corporation (NLC) Here

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CHINA

Chinese labelling laws The key items of labelling legislation are the wine standard (GB 15037) and the wine labelling law (GB 10344) both of which are administered by the General Administration of Quality Supervision, Inspection and Quarantine of the People’s Republic of China. As there are significant difficulties involved in interpreting and translating these standards, we strongly advise that you consult your agent in the relevant market to confirm the requirements before labelling your wine.

Mandatory information Presentation and placement Wines sold in the Chinese market must bear mandatory information in Chinese characters. This means that a special label needs to be produced for the Chinese market. The minimum type size for most mandatory label information is 1.8mm.

Chinese law bans the use of temporary adhesive labels, although some foreign wineries continue to attach small and simple labels (translated into Chinese) on the outside of the bottle.

This is done either prior to delivery to China or by the Chinese importer under the supervision of a Chinese inspection and quarantine organisation. This is a risky option to take and, as such, New Zealand Trade and Enterprise recommends that exporters strictly abide by the formal labelling regulations when developing business in China.

Product name The name of the product is mandatory in China. The words ‘grape wine’ should be sufficient, however it is advisable to qualify this with ‘red’, ‘white’, ‘sparkling’, ‘semi-sparkling, ‘fortified’, ‘sweetened fortified’ etc. The minimum type size is 1.8mm. This may appear on any label.

Country of Origin A country of origin statement is mandatory. Importers will usually request a Certificate of Origin to confirm this claim.

Certificates of Origin can be obtained from WECS or your local Chamber of Commerce. The minimum type size is 1.8mm. This may appear on any label.

Alcohol by volume The alcohol declaration should be in the form ‘Alcoholic strength xx.x% vol’. (Apparently % Mass is also acceptable and this may account for some of the reported disparity between results obtained from testing authorities within China). The tolerance between the actual and the stated alcohol is +/- 1.0% in China.

The minimum type size is 1.8mm.

Net contents The net contents must be on the same display panel as the word ‘wine’. This should be marked as ‘net content xxx Ml (ml)’ for bottle sizes under a litre, or ‘net content x Litres (l)’ for bottle sizes over a litre. For packages up to and including 200ml the minimum print height is 3mm. From 200ml up to and including 1 litre the minimum print height is 4mm. For packages greater than 1 litre the minimum print height is 6mm.

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Importer The name and address of the Chinese agent, importer or distributor must be shown on the label. The name and address of the producer is not mandatory, however if included it does not need to be translated into Chinese characters. The minimum type size is 1.8mm. This may appear on any label.

Lot identification The date of bottling is required on Chinese labels. The minimum type size is 1.8mm. This may appear on any label.

Compliance with this requirement could be extremely difficult as the standard batch or lot labelling using the Julian date code does not appear to be acceptable to the Chinese. Neither can the bottling date be applied in the form of a sticker, reprint or tampering which suggests that the label itself must contain the required information. We suggest that negotiation with your bottler is required in order to satisfy this traceability requirement.

Best before date Wines with an alcohol content of 10% or less are required to include a minimum durability date. The minimum type size is 1.8mm. This may appear on any label. Wines over 10% alcohol are exempt from this requirement (GB7718-5.2.1 and GB103445.2). Nevertheless many importers and/or regulatory authorities seem unaware of this exemption and it is advisable to include a statement such as ‘recommended to drink before (year)’.

Ingredients Only products made from a single raw material are exempt from the requirement for ingredient listing. This means that sweeteners, preservatives and added colour (legal in the case of fortified wine only) need to be declared in descending order of their weight. Ingredients constituting less than 2% of the food are not required to be listed in descending order.

The list of ingredients for wine should have the title of “raw material” or “raw material and auxiliary material”. The name of the substance (sulphur dioxide, sorbic acid etc) should be declared rather than the generic category, for example, ‘preservative’ or ‘colour’. Added acids should also be declared.

It is not necessary to list processing aids (although it is worth noting that there is a proposal in draft form for allergenic processing aids to be labelled). The minimum type size is 1.8mm.

This may appear on any label.

Health advisory A recent amendment to the Chinese wine standard requires all labels to include a health warning. As far as we are aware, the form of the wording is flexible, but the recommended text is: “excessive drinking may cause harm to your health”.

Sweetness level The sweetness level (product type) is also mandatory for China. This can be indicated by the actual sugar content or by the category.

The following categories apply: Dry wines

Wines with a sugar content (measured by grape glucose) less than or equal to 4.0g/l; or wines with a maximum sugar content of 9.0g/l when the difference between total sugar and total acids (measured by tartaric acids) is less than or equal to 2.0g/l

Semi-dry wines

Wines with a sugar content greater than that of dry wines or with a maximum sugar content of 12.0g/l; or wines with a maximum sugar content of 18.0g/l when the difference between total sugar and total acids (measured by tartaric acids) is less than or equal to 2.0g/l

Semi-sweet wines

Wines with a sugar content greater than that of dry wines or with a maximum sugar content of 45.0g/l

Sweet wines

Wines with a sugar content greater than 45.0g/l

Still wines

Wines with carbon dioxide pressure of less than 0.05 MPa at 20oC

Sparkling wines

Aerated wines with carbon dioxide (completely produced by natural fermentation) pressure greater than 0.35 MPa at 20oC (for bottles with a capacity of less than 250 ml and with carbon dioxide pressure greater than or equal to 0.3 MPa) –– Brut sparkling wines: sparkling wines with a sugar content of less than or equal to 12.0g/l (tolerable deviation: 3.0g/l) –– Extra-dry sparkling wines: sparkling wines with a sugar content within the range of 12.1-17.0g/l (tolerable deviation: 3.0g/l) –– Dry sparkling wines: sparkling wines with a sugar content within the range of 17.1-32.0g/l (tolerable deviation: 3.0g/l) –– Semi-dry sparkling wines: sparkling wines with a sugar content within the range of 32.150.0g/l –– Sweet sparkling wines: sparkling wines with a sugar content greater than 50.0g/l Semi-sparkling wines Aerated wines with carbon dioxide (completely caused by natural fermentation) pressure within the range of 0.05-0.34 MPa at 20oC

Liqueur wines

Wines made from grapes, with a total alcohol content of above 12% (volume fraction), with the addition of grape brandy, edible alcohol or wine essence, grape juice, grape juice concentrate, caramel grape juice, white sugar, etc, so that the final product has an alcohol content of 15.022.0% (volume fraction)

Carbonated wines

Wines whose carbon dioxide is partially or completely added artificially, and which have similar physical properties to those of aerated wines

Ice wines

Wines made from frozen grapes which are kept hanging on the branches at below -7oC for a certain period of time, and then picked for pressing and fermentation (no sugar source may be added in the wine-making process)

Noble rot wines

Wines made from grapes which are infected with Botrytis cinerea in the later stages of the ripening period, as a result of which obvious changes have occurred to the ingredients of the fruits

Optional information Vintage, variety, and geographic indications can be used. You must comply with the New Zealand thresholds if you wish to include these.

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JAPAN

Japanese labelling laws

Carbonation statement

Wine for sale must comply with the labelling standard regulations based on the Law Concerning Liquor Business Association and Measures for Securing from Liquor Tax, the Food Sanitation Law, and the Measurement Law. For imported wines, both importing and wholesaling companies are responsible for indicating the following on product labels.

A statement is required as to whether or not a wine is carbonated. The minimum type size is 2.8 mm. This must appear collectively with product name, alcohol content, country of origin, food additives.

Mandatory information Mandatory information on the label must be in Japanese.

This means that a special label needs to be produced for the Japanese market. The minimum type size for most mandatory information is 2.8mm.

Product name This should be a common name, such as “wine”. The minimum type size is 2.8mm. This must appear in conjunction with alcohol content, country of origin, food additives, carbonation statement.

Health advisory All wine labels should bear one of the following statements: “Consumption of alcohol by minors is prohibited” or “Alcohol may only be consumed by those 20 or over”. The minimum type size is 2.8mm.

Optional information Vintage, variety and geographical indication claims are optional.

You should comply with the New Zealand thresholds if you wish to include these.

Health advisory

This can be done in the usual form – e.g. “New Zealand Wine”.

The minimum type size is 2.8mm. This must appear collectively with product name, alcohol content, food additives, and carbonation statement.

A health warning on the label is a voluntary industry standard and relates to the risks of alcohol to pregnant and breast-feeding women. The advisory statement should warn pregnant and nursing women that the consumption of alcohol may adversely affect their infant’s health. For example, “Drinking alcohol while pregnant or breast-feeding may harm the foetus or infant.”

Alcohol by volume

Environmental, sustainability and organic claims

This should be rounded to the nearest percentage point and be expressed as follows: “x degrees or more to less than y degrees alcoholic content”. The difference between x and y must be no more than 1 degree of alcoholic content. So, for example, a wine with 12.6% alcohol should be labelled: “12 degrees or more to less than 13 degrees alcohol.” The minimum type size is 2.8 mm. This must appear collectively with product name, country of origin, food additives, and carbonation statement.

In order to be able to use organic labelling in Japan, your product must meet the requirements of the Japan Agricultural Standards (JAS) law. New Zealand producers can arrange to be certified in New Zealand under MPI’s organic programme, which is recognized by JAS. Use of the term “Organic” must comply with a Codex Alimentarius-based labelling standard.

Country of Origin

Net Contents This can be expressed in either millilitres or litres. The minimum type size is 2.8 mm.

Importer The name and address of the importer must appear on the label.

Details must be sufficient to allow a consumer to contact the importer. If the distributor is different from the importer, the distributor’s details should also appear. The minimum type size is 2.8mm.

Ingredient listing The names of any food additives should be shown in descending order of proportion by weight. Relevant additives are preservatives or antioxidants, which should be listed preceded by the word “preservative” or “antioxidant” (examples provided by the Japanese Government are SO2, sorbate and ascorbate). The minimum type size is 2.8 mm. This must appear collectively with product names, alcohol content, country of origin, carbonation statement.

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A voluntary carbon footprint (CF) labelling pilot was launched by the Japanese Government in 2009. Participating products must indicate in numerical form the estimated CO2 emissions created during the product’s life cycle. If you are interested in participating, contact New Zealand Winegrowers for more information on the scheme.

SOUTH KOREA

South Korea’s labelling laws

Importer

Importers must obtain a license from the regional tax office to import alcoholic beverages including wine. The import of wine is not restricted in Korea, but is subject to inspection by the Korea Food & Drug Administration (KFDA). For any initial shipment into the market, a close inspection usually takes 18 days.

Inspections of subsequent shipments usually take three to four days if the product is identical in label, product name, alcoholic content, vintage and bottle size. For more information see nzte.

The importer name, address and phone number must appear on the label and must be sufficient to enable the consumer to identify and contact the importer so that returned products can be exchanged if defective. You should also include the importer’s Business License Number (which can be obtained from your importer).

Mandatory information

Brand name The label must bear a brand name. This must be at least 2.1mm in height and must appear on front label.

Presentation and placement Mandatory information must be written in Korean. English can appear on the label with Korean, but these words should be equal to or less than the size of the Korean letters. Country of origin, product/brand name, and the name and address of the overseas manufacturing company do not have to be translated into Korean. Stickers may be used but should not be easily removable, or cover the original labelling. Korean food importers can prepare labels in Korean and stick to bottles in a bonded warehouse in Korea prior to customs clearance.

Product name The product type ‘grape wine’ may be further classified by colour as either ‘red wine’, ‘white wine’ or ‘rose wine’. The height of the product type is relative to the height of the product name. If the product name is less than 7.76mm, the product type must be at least 2.47mm. If the product name is greater than 7.76mm, the product type must be at least 4.23mm. The product type must also appear on the front label.

Country of Origin The country of origin must be labelled in a conspicuous place and be legible, indelible, and permanently marked.

Lot identification Alcoholic beverages must have one of the following labelled on the product: (1) Date of manufacture; (2) Bottling Date; or (3) Manufacturing Serial Number (i.e. Lot Number or Code). This information must appear on the Collective Display Panel.

Date of Manufacture should be written: “yy.mm.dd”, or “yyyy.mm.dd” or “yyyy/mm/dd”.

Bottling Date should be written: “yy.mm.dd”, or “yyyy.mm.dd” or “yyyy/mm/dd”.

This must appear on the same label as the ingredient and additives list.

Storage instructions Storage instructions must appear on the label. The format is not specified.

Carbonation statement Carbonated products must indicate on the label that they are carbonated.

Ingredient list

An alcohol declaration is mandatory in Korea. The format is not prescribed by the regulations. The KFDA test whether the alcohol content maintains a 0.5% tolerance level between the labelled and actual alcoholic content.

The ingredient(s) used must be listed in descending order of weight or proportion. Food additives must also be listed. We understand that the following statement may be used to satisfy this requirement: “Raw material: 100% grape juice.” “Sulfur dioxide (anti-oxidant) used” or words to that effect. These must appear on the same label as the date of bottling.

Net contents

Health advisory

Net contents must appear on the front label. No format is specified.

The following two statements are mandatory:

Alcohol content

Producer The name of the producer must appear on the label and can be stated in English. (“Made by company name, address and country name”).

“Excessive drinking may cause liver cancer or liver hardening and raise accident rate during driving or working” AND “Warning: sale to people less than 19 years old is prohibited”.

Mode of Distribution The label should specify one of the three: “Discount Store Sale only,” “Restaurant Sale only,” or “Sale for Home Use only.”

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Recycling mark The label should carry a recycling mark. The format is not specified.

Return and exchange office details The label should list return and exchange office details to facilitate consumer service / complaints. Your distributor should advise you on the details to appear on the label.

Optional information Vintage, variety and Geographical Indication claims are optional.

If you use them, you should comply with the New Zealand thresholds.

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RUSSIA

Russian labelling laws

Nutritional information

The following summary of the Russian labelling regulations is drawn from information provided by Market New Zealand and the Australian Wine and Brandy Corporation. However, there are significant difficulties involved in interpreting and translating these standards and we strongly advise caution in applying the following information. Note that Russia has proposed new labelling laws. It is not clear when these will come into force. You should consult your agent in the relevant market to confirm the requirements before labelling your wine.

It is mandatory to declare the number of calories per 100mL of wine.

Mandatory information

Special Excise Duty Stamp All alcoholic beverages imported into Russia must contain the Special Excise Duty Stamp. Alcohol cannot be sold in Russia without the stamp. This is typically applied in Russia by the importer. Products intended for sale at duty-free shops should bear the indication “Only for sale in duty-free shops” on the label and counter-label.

Product name

Optional information

All wine labels must bear the term “grape wine”, and we are advised that this should be qualified with “red” or “white”.

Vintage, variety and geographical indication claims are optional, but if a geographical indication is used you must include a vintage date.

Country of origin A country of origin statement is mandatory on all imported products.

Alcohol content The preferred form is % of total volume.

Net contents The volume statement must appear on the label in either L, or mL.

What else you should know In order to avoid paying higher excise, wine should fit within the Russian Federal Customs Service definition of ‘natural wine’ which is: “The wine must not have more than 15 percent ethyl alcohol, and must be made as a result of full or partial fermentation of whole or crushed berries, fresh grapes, or fresh grape must (Unfermented or fermented juice of grapes). Moreover, they may not contain added ethyl alcohol or additives influencing taste and/or smell.”

Importer / producer The name and address of both the importer and the exporter must be shown on the label. The address must be sufficient to enable the consumer to identify and contact the importer.

Lot identification Information on the date and place of bottling and production is required.

Health advisory All wine labels must include the following health warning: “Alcohol is not for children and teenagers up to age 18, pregnant and nursing women, or for persons with diseases of central nervous system, kidneys, liver and other digestive organs”.

In addition to the health warning, the label must carry a statement of counter-indication against consumption of alcohol beverages. Contact your agent for information on the wording for this statement.

Ingredient list In addition to a list of the ingredients contained in the alcohol, it is also mandatory to include names of food supplements, biologically active supplements and any genetically modified organisms used in the wine’s production.

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BRAZIL

Brazilian labelling laws

Mandatory information

Brazilian labelling requirements are found in the Brazilian Consumer Protection Law number 8,078. As there are significant difficulties involved in interpreting and translating these requirements we strongly advise caution in applying the following information. You should consult your agent in the relevant market to confirm the requirements before labelling your wine.

United States Department of Agriculture reports state that it is common practice in Brazil for importers, agents, or distributors to affix to the wine bottle an additional small adhesive label in Portuguese, with the name and address of the importer and the company’s tax registration number.

Once the product reaches Brazil, in order to clear customs, imported wines are subject to chemical analysis to verify that they meet international requirements. Port authorities working for the Ministry of Agriculture will take one sample for analysis.

The Brazilian importer will deposit the imported merchandise in storage until the laboratory test results are confirmed.

The following information must also appear on the label: • Product name • Country of origin • Alcohol declaration • Net contents (in metric units) • Validity date (shelf life) • Date of production • Food Additives (if any)

Product name The following categories of wine are recognised by Brazilian authorities: a. Table wine (including effervescent table wine) b. Natural sparkling wine c. Carbonated sparkling wine d. Liqueur wine e. Fortified wine

Geographical Indications Geographical indications must not be used to describe wines exported to Brazil unless the geographical indications are included in Annex 2 of this Guide.

Wine is further categorised based on total sugar content:

a. Table wine

i. Dry – maximum of 5.0 g/L glucose ii. Medium dry – between 5.1 and 20.0 g/L glucose iii. Sweet/Mild – minimum of 20.1 g/L glucose

b. Sparkling wine (Champagne)

i. Gross (Brut) – maximum of 15 g/L glucose ii. Extra dry/Dry – between 15.1 and 20.0 g/L glucose iii. Medium dry/Medium sweet – between 20.1 and 60.0 g/L glucose iv. Sweet – minimum of 60.1 g/L glucose

c. Carbonated sparkling wine

i. Dry – maximum of 20 g/L glucose ii. Medium sweet/Medium dry – between 20.1 and 60.0 g/L glucose iii. Sweet – minimum of 60.1 g/L glucose

d. Liqueur wine

i. Dry – maximum of 20.0 g/L glucose ii. Sweet – Minimum of 20.1 g/L glucose

e. Fortified wine

i. Dry – maximum of 40.0 g/L glucose ii. Medium sweet – between 40.1 and 80.0 g/L glucose iii. Sweet – minimum of 80.1 g/L glucose

Fine table wine is classified as wine made from Vitis vinifera grapes.

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OTHER ASIAN COUNTRIES We have included below information on the labelling requirements of several key Asian markets. This information is not as detailed as that provided for other markets, due to the difficulty of obtaining up to date and accurate material from these markets. It is intended to give you an overview of the sorts of labelling issues you will need to consider when exporting to those markets. You should consult your agent in the relevant market to confirm the requirements before labelling your wine.

This information is taken directly from the acknowledged sources, largely without commentary from us. Where we have commented, this appears in italics. Our key source is the excellent set of market reports provided courtesy of New Zealand Trade and Enterprise. We highly recommend that you explore this free resource for yourself at nzte.

Hong Kong Wine or alcoholic drinks with an alcoholic strength by volume of 10% or more as determined under section 53 of the Dutiable Commodities Ordinance (Cap 109) (L.N. 85 of 2004; L.N. 139 of 2004) are exempted from Schedules 3 of the Food and Drugs (Composition and Labelling) Regulations except paragraph 3 (see details on the website www.fehd.gov.hk ).

In effect, this appears to mean that the general food labelling standards do not apply to wine, although there is a requirement for an alcohol declaration in other legislation. Nevertheless, it is very likely that importers/distributors will have their own additional requirements for wine labels.

Thailand Imports of alcoholic beverages including wine are under the responsibilities of The Excise Department (EXD) and The Customs Department. The EXD’s responsibilities include labelling, licensing, and product quality control. The following nine items must appear on the same label in either English or Thai (except for the health warning, which must appear in Thai): • • • • • • • • •

brand name product name alcohol content country of origin importer or producer’s name and address (not postal) health warning (see below) volume statement food additives (must state “preservatives used”) lot number

In 2003, the Ministry of Public Health put in place new requirements for a health warning on individual bottles. The label must be in Thai, legible, bold letter at least 2 mm height. The following statement may be used: “Drinking alcoholic beverages decreases driving ability”

Malaysia The Malaysian Food Regulations 1985 prescribe that the following seven items must appear “conspicuously” and “prominently” on the same label in either English or Bahasa Malaysia: • product name (ie “wine”) – 3.5mm • alcohol statement (must state, in capital, bold lettering: “ARAK MENGANDUNGI - %ALKOHOL”) – 4.2mm • country of origin – 1.5mm • importer’s name and address (not postal) – 1.5mm • volume statement – 3.5mm • food additives (must state “contains permitted [additive]”]) – 1.5mm • lot number Singapore There are no specific wine standards or labelling requirements in Singapore, but wine products are subject to the general food standards and labelling requirements.

The following basic items are required to be declared on labels in English: Product name A common name or a description which is sufficient to indicate the true nature of the food product should be included. The common name for wine shall also mean any words indicating the specific type of grapes from which the wine is made or the locality from which the grapes used originated or the locality in which the wine was made.

Country of origin The name of the country of origin of the food should be indicated on the label for imported food.

Alcohol content The format for this is not prescribed.

Net contents The net quantity of the food in the package expressed in terms of volumetric measure (eg. ml, litres) or net weight (eg, g,kg) or any other measure should be printed on the label to indicate the quantity of the contents. In the case of weight measure, suitable words like “Net” shall be used to describe the manner of measure.

Importer In the case of an imported food, the label should indicate the name and address of the local importer, distributor or agent.

Telegraphic, facsimile and post office address are not acceptable.

Allergen statement Allergen labelling is now required for all wine imported into Singapore containing ‘ingredients known to cause hypersensitivity’ (egg, milk products or sulphites over 10ppm).

Wine fined with isinglass or fish gelatin is exempt from the requirements. The form is “contains: milk”. More information can be found here on the Singapore Agri-Food Authority’s website.

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India

Taiwan

The key items of labeling legislation are the Prevention of Food Adulteration Rules 1955 and the Standards of Weights and Measures (Packaged Commodities) Rules 1977.

It is compulsory for imported wine to carry a Chinese language label. Stickers may be used but should not be easily destroyed or damaged. Labels should include the following mandatory information printed clearly and legibly:

The following six items must appear on the Principal Display Panel (PDP)4 in either English or Hindi in Devnagri script: • • • • • • •

name of product ingredient list name and address of manufacturer and importer volume statement lot number packaging date The following two items of information may appear anywhere on the label • alcohol statement (no prescribed format – you may use the New Zealand calculation method) • country of origin The minimum print height is 1mm, however the volume statement, lot number and packaging date must be at least 4mm. Ingredients must be listed in descending order of their composition by weight or volume. If gelatine is used as an ingredient, the following declaration must be included: “Gelatine – Animal Origin.” Antioxidants and preservatives must be declared and prefaced with the word “Antioxidant” or “Preservative”.

If the wine contains any animal products including birds, eggs or fish (but not including milk or milk products) a symbol indicating that the product is non-vegetarian must be included on the label.

The symbol is a brown circle inside a square with a brown outline (the square must be twice the diameter of the circle):

• • • • • • • •

brand name (may be in English) product type country of origin alcohol statement (must be labeled by degrees eg XX% vol) health warning producer’s name and address importer’s name and address lot number (imported wine harvested and produced only once a year should adopt its date of manufacture as its lot number) • sulphur dioxide statement (wine containing more than 250mg/L but less than 400 mg/L of sulphur dioxide must be labeled: ‘this product contains less than 400 ppm of sulphur dioxide’) Vintage, variety and geographical indication claims are optional.

If wines of different ages are blended, the label can only refer to the youngest one.

Philippines The importation of wine into the Philippines is regulated by its Food and Drug Administration (FDA). Labels should include: • • • • •

the name of the product country of origin ethyl alcohol content (% alcohol by volume or proof) name and address of the manufacturer contents in millilitres

Indonesia

AREA OF PRINCIPAL DISPLAY PANEL (PDP)

MINIMUM DIAMETER

Up to 100 cm square.

3 mm

100 cm square to 500 cm square

4 mm

500 cm square to 2500 cm square

6 mm

Above 2500 cm square.

8 mm

The symbol must be displayed in close proximity to the PDP on a contrasting background and should be included on any associated containers, pamphlets, leaflets or advertising material.

A similar symbol is required for vegetarian food – a green circle inside a green square. The display requirements are the same as for the Non-vegetarian symbol.

4

For cylindrical containers the PDP must cover at least 20% of the height and circumference of the container, neck not included.

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The National Agency of Drug and Food Control (NADFC) is responsible for issuing permits for wine imported into Indonesia, and for its inspection, any laboratory testing, and the exercise of related investigation and enforcement powers. Imported wine must be manually registered with the NADFC before being distributed for sale.

The importation of alcoholic beverages into Indonesia is quotabased and importers must be appropriately registered. Product packaging requirements are governed by the Standar Nasional Indonesia, or “SNI”. The SNI apparently references the Codex Alimentarius. For alcoholic beverages, compliance with the SNI product packaging requirements is voluntary.

The NADFC requires that labels: are not easily separated from the product; are not easily worn or damaged; and are located on the product in a way that is easy to see and read.

The following information must appear on the label: • • • • • • • • •

the product name net contents name and address of the manufacturer ingredients list food registration number expiry date; production code health warning alcohol content

Annex 1 – Appellations of origin for use in the USA

The following is the list of appellation of origin approved for use on NZ wines in the USA. Akaroa

East Coast

Marlborough

Selwyn

Alexandra

Flaxmere

Martinborough

South Island

Ahuriri

Galatea

Masterton

Tamahere

Amberley

Gisborne

Matakana

Tasman

Auckland

Golden Bay

Mohaka

Taupo

Awatere

Great Barrier Island

Motueka

Tauranga

Awatere Valley

Hamilton

Moutere

Waiheke Island

Bay of Islands

Haumoana

Napier

Waikato

Bay of Plenty

Hauraki Gulf Islands

Nelson

Waimea

Bethlehem

Havelock North

New Zealand

Waipara Valley

Blenheim

Hawkes Bay

North Canterbury

Wairarapa

Cambridge

Hawke’s Bay

North Island

Wairau

Canterbury

Henderson

Northland

Wairau Valley

Central Hawkes Bay

Heretaunga

Otago

Wairoa

Central Otago

Kahuranaki

Otaki

Waitakere

Christchurch

Kaikohe

Paeroa

Waitaki Valley

Clevedon

Kapiti

Patutahi

Wanaka

Clive

Katikati

Pokeno

Wanganui

Coromandel

Kerikeri

Pukekohe

Wellington

Cromwell

Kumeu

Queenstown

Whakatane

Dargaville

Lake Taupo

Richmond

Whangarei

Drury

Mangere

Rotorua

Earnscleugh

Maraekakaho

Roxburgh

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Annex 2 - Geographical Indications for use in the EU and Brazil

The following list sets out the geographical indications for use in the European Union and Brazil. The list is based on the outcomes of the 2006 industry GI survey, the GI Summit of December 2008 as well as consultations with regional associations and individuals throughout the country.

GEOGRAPHICAL INDICATION

DEFINED AREA

NEW ZEALAND

The country of New Zealand

EAST COAST

Northland Region, Auckland Region, Bay of Plenty Region, Coromandel District, Hauraki District, Gisborne Region, Hawkes Bay Region, Masterton District, Carterton District, South Wairarapa District, Marlborough District, Canterbury Region

NORTH ISLAND

The North Island of New Zealand

Northland

Northland Region

Auckland

Auckland Region

Clevedon

Winegrowing area in Auckland Region

Western Auckland (comprising Henderson, Huapai, Kumeu, Waimauku)5

Winegrowing area in Auckland Region

For wines bearing a geographical indication, at least 85% of the grapes from which the wine is produced must be derived from the stated geographical indication. Such wines must display the quality, reputation or other characteristics attributable to their origin.

Matakana

Winegrowing area in Auckland Region

Waiheke Island

Waiheke Island

Waikato

Waikato Region

Coromandel Peninsula

Thames-Coromandel District

In order to use the name of a geographical unit other than a listed GI in the EU, the name of a listed GI must feature on the label in the appropriate position (see page 31). In the case of smaller geographical unit, at least 85 % of the grapes from which the wine has been produced must originate in that smaller geographical unit. The remaining 15% of the grapes must be derived from the stated geographical indication.

Lake Taupo

Taupo District

Te Kauwhata

Winegrowing area in Waikato Region

Bay of Plenty

Bay of Plenty Region

Gisborne

Gisborne Region

Hawke’s Bay

Hawke’s Bay Region

Any of the following may be considered a geographical unit/ reference for the purposes of EU labelling regulations, provided that they are well defined:

Central Hawke’s Bay

Central Hawke’s Bay District

Wairarapa

Carterton, Masterton and South Wairarapa Districts

Gladstone

Defined winegrowing area In Carterton District

Martinborough

Defined winegrowing area in Martinborough Ward

Wellington

Greater Wellington Region

SOUTH ISLAND

The South Island of New Zealand

Marlborough

Marlborough and Kaikoura Districts

Nelson

Nelson and Tasman Districts

Canterbury

Canterbury Region

North Canterbury

Waimakariri and Hurunui Districts

Waipara Valley

Winegrowing area in Hurunui District6

Waitaki Valley

Winegrowing area in Waitaki and Waimate Districts

Central Otago

Central Otago and Queenstown Lakes Districts

Included on the list are only those GIs that have a history of use by a number of companies as “stand alone” GIs - i.e. they are not used in conjunction with or subordinate to another GI. Each of these GIs has clearly defined boundaries and agreement across the relevant area as to its name.

However, exporters can still use the names other geographical units on the label alongside a listed GI, provided that they comply with the rules set out below. This means that new or developing regions can still appear on the label in conjunction with a listed GI (e.g. Ohau, North Island). It also means that subordinate geographical units can appear in conjunction with a listed GI (e.g. Te Awanga, Hawkes Bay; Awatere Valley, Marlborough). Larger geographical units may also be used (e.g.

Waitaki Valley, North Otago).

Use of geographical references

(a) a locality or group of localities (b) a local administrative area or part thereof (c) a wine-growing sub-region or part thereof (d) an administrative area

Each of these names may be used individually instead of “Western Auckland” where appropriate.

5

“Waipara” may be used as an alternative to “Waipara Valley”.

6

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Annex 3 - EU Allergen Declarations

The following lists provide an indication based on the best information we have to date about the forms of allergen declaration that will be acceptable in various EU Member States.

The permitted languages and translations for the sulphites statement are provided in Annex 3A. The permitted languages for the milk and/or egg statement are set out in Annex 3B and the permitted wording/translations in Annex 3C. The translations for the word “contains” were not officially issued and are based on our previous advice on sulphite declarations. We encourage you to confirm the final form of your statement with your agent.

You can also choose to use one of the official pictograms in Annex 3D. The pictograms are not compulsory and must still be accompanied with the “contains milk/egg” statements.

Annex 3A - Permitted Languages/ Translations (Sulphites) MEMBER STATE

TRANSLATION

Austria

German (Enthält Sulfite)

Belgium

Dutch (Bevat sulfieten) English (Contains Sulphites) French (Contient sulfites) German (Enthält Sulfite)

Cyprus

Greek (Περιέχει θειώδη)

Czech Republic

Czech (Obsahuje siřičitany)

Denmark

Danish (Indeholder sulfitter) Swedish (Innehåller sulfiter)

Estonia

Any EU language (NB Estonian = Sisaldab sulfitid)

Finland

Finnish (Sisältää sulfiitteja) Swedish (Innehåller sulfiter).

Swedish can be replaced by Danish or Norwegian.

France

French (Contient sulfites) English (Contains Sulphites)

Germany

German (Enthält Sulfite)

Greece

Greek (Περιέχει θειώδη)

Hungary

Hungarian (Tartalmaz szulfitok)

Ireland

English (Contains sulphites / Contains sulfites)

Italy

Italian (Contiene solfiti)

Latvia

Latvian (Satur sulfīti)

Lithuania

Lithuanian (Sudėtyje yra sulfitai)

Luxembourg

French (Contient sulfites) English (Contains sulphites) Lux

Malta

Maltese (Fih sulfiti) English (Contains Sulphites) Italian (Contiene solfiti)

Poland

Polish (Zawiera siaraczyny)

Portugal

Portuguese (Contém sulfitos) English (Contains Sulphites) Spanish (Contiene sulfitos) French (Contient sulfites)

Slovakia

Slovakian (Obsahuje siřičitany)

Slovenia

Slovenian (Vsebuje sulfiti)

Spain

Spanish (Contiene sulfitos) Portuguese (Contém sulfitos) English (Contains Sulphites) French (Contient sulfites) Italian (Contiene solfiti)

Sweden

Swedish (Innehåller sulfiter) English (Contains Sulphites)

The Netherlands

Dutch (Bevat sulfieten)

United Kingdom

English (Contains Sulphites / Contains sulfites)

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Annex 3B - Permitted Languages (Milk/Egg)

MEMBER STATE

WITHOUT PICTOGRAM

WITH PICTOGRAM

Belgium

Dutch, French, German or English

Dutch, French, German, English + pictogram

Bulgaria

Bulgarian

Bulgarian + pictogram

Czech Republic

Czech

Czech + pictogram

Denmark

Danish

Danish + pictogram

Germany

German

German + pictogram

Estonia

Any EU language

Any EU language + pictogram

Ireland

English and/or Gaelic

English and/or Gaelic + pictogram

Greece

Greek

Greek + pictogram

Spain

Spanish

Spanish + pictogram or Spanish (English or French or Italian or Portuguese) + pictogram

France

French

French and/or any other EU language + pictogram

Italy

Italian

Italian and or any other EU language + pictogram

Cyprus

Greek

Greek + pictogram

Latvia

Latvian

Latvian + pictogram

Lithuania

Lithuanian

Lithuanian + pictogram

Luxembourg

French or German

French or German + pictogram

Hungary

Hungarian

Hungarian + pictogram

Malta

Maltese, English or Italian

Maltese, English or Italian + pictogram

The Netherlands

Dutch

Dutch + pictogram

Austria

German

English + pictogram

Poland

Polish

Polish + pictogram

Portugal

Portuguese, English, French or Spanish

Portuguese and or any other EU language + pictogram

Romania

Romanian

Romanian, French, German or English + pictogram

Slovenia

Slovenian

Slovenian + pictogram

Slovakia

+ pictogram

Finland

Finnish and Swedish (Swedish can be replaced by Danish or Norwegian)

Finnish and Swedish (Swedish can be replaced by Danish or Norwegian) + pictogram

Sweden

Swedish

Swedish + pictogram

United Kingdom

English

English + pictogram

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Annex 3C - Permitted Wording (Sulphites/Egg/Milk)

LANGUAGE

SULPHITES

EGG PRODUCTS

MILK PRODUCTS

Bulgarian

„сулфити” or „серен диоксид”

„яйце”, „яйчен протеин”, „яйчен продукт”, „яйчен лизозим” or „яйчен албумин”

„мляко”, „млечни продукти”, „млечен казеин” or „млечен протеин”

Spain

«sulfitos» or «dióxido de azufre»

«huevo», «proteína de huevo», «ovoproducto», «lisozima de huevo» or «ovoalbúmina»

«leche», «productos lácteos», «caseína de leche» or «proteína de leche»

Czech

„siřičitany” or „oxid siřičitý”

„vejce”, „vaječná bílkovina”, „výrobky z vajec”, „vaječný lysozym” or „vaječný albumin”

„mléko”, „výrobky z mléka”, „mléčný kasein” or „mléčná bílkovina”

Danish

»sulfitter« or »svovldioxid«.

“æg”, “ægprotein”, “ægprodukt”, “æglysozym”, or “ægalbumin”

“mælk”, “mælkeprodukt”, “mælkecasein” or “mælkeprotein”,

German

„Sulfite” or „Schwefeldioxid”

„Ei”, „Eiprotein”, „Eiprodukt”, „Lysozym aus Ei” or „Albumin aus Ei”

„Milch”, „Milcherzeugnis”, „Kasein aus Milch” or „Milchprotein”

Estonian

„sulfitid” or „vääveldioksiid”

„muna”, „munaproteiin”, „munatooted”, „munalüsosüüm” or „munaalbumiin”…

„piim”, „piimatooted”, „piimakaseiin” or „piimaproteiin”

Greek

«θειώδη», «διοξείδιο του θείου» or «ανυδρίτης του θειώδους οξέος»

«αυγό», «πρωτεΐνη αυγού», «προϊόν αυγού», «λυσοζύμη αυγού» or «αλβουμίνη αυγού»

«γάλα», «προϊόντα γάλακτος», «καζεΐνη γάλακτος» or «πρωτεΐνη γάλακτος»

English

‘sulphites’, ‘sulfites’, ‘sulphur dioxide’ or ‘sulfur dioxide’

‘egg’, ‘egg protein’, ‘egg product’, ‘egg lysozyme’ or ‘egg albumin’

‘milk’, ‘milk products’, ‘milk casein’ or ‘milk protein’

French

«sulfites» or «anhydride sulfureux»

«œuf», «protéine de l’œuf», «produit de l’œuf», «lysozyme de l’œuf » or «albumine de l’œuf»

«lait», «produits du lait», «caséine du lait» or «protéine du lait»

Italian

«solfiti», or «anidride solforosa»

«uovo», «proteina dell’uovo», «derivati dell’uovo», «lisozima da uovo» or «ovoalbumina»

«latte», «derivati del latte», «caseina del latte» or «proteina del latte»

Latvian

„sulfīti” or „sēra dioksīds”

„olas”, „olu olbaltumviela”, „olu produkts”, „olu lizocīms” or „olu albumīns”

„piens”, „piena produkts”, „piena kazeīns” or „piena olbaltumviela”

Lithuanian

„sulfitai” or „sieros dioksidas”

„kiaušiniai”, „kiaušinių baltymai”, „kiaušinių produktai”, „kiaušinių lizocimas” or „kiaušinių albuminas”

„pienas”, „pieno produktai”, „pieno kazeinas” or „pieno baltymai”

Hungarian

„szulfitok” or „kén-dioxid”

„tojás”, „tojásból származó fehérje”, „tojástermék”, „tojásból származó lizozim” or „tojásból származó albumin”

„tej”, „tejtermékek”, „tejkazein” or „tejfehérje”

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Annex 3C - Permitted Wording (Sulphites/Egg/Milk) cont.

LANGUAGE

SULPHITES

EGG PRODUCTS

MILK PRODUCTS

Dutch

“sulfieten” or “zwaveldioxide”

“ei”, “eiproteïne”, “eiderivaat”, “eilysozym” or “eialbumine”

“melk”, “melkderivaat”, “melkcaseïne” or “melkproteïnen”

Polish

„siarczyny”, „dwutlenek siarki” or „ditlenek siarki”

“jajo”, “białko jaja”, „produkty z jaj”, “lizozym z jaja” or “albuminę z jaja”

“mleko”, “produkty mleczne”, “kazeinę z mleka” or “białko mleka”

Portuguese

«sulfitos» or «dióxido de enxofre»

«ovo», «proteína de ovo», «produto de ovo», «lisozima de ovo» or «albumina de ovo»

«leite», «produtos de leite», «caseína de leite» or «proteína de leite»

Romanian

„sulfiți” or „dioxid de sulf”

„oră”, „proteine din oră”, „produse din oră”, „lizozimă din oră” or „albumină din oră”

„lapte”, „produse din lapte”, „cazeină din lapte” or „proteine din lapte”

Slovakian

„siričitany” or „oxid siričitý”

„vajce”, „vaječná bielkovina”, „výrobok z vajec”, „vaječný lyzozým” or „vaječný albumín”

„mlieko”, „výrobky z mlieka”, „mliečne výrobky”, „mliečny kazeín” or „mliečna bielkovina”

Slovenian

‘sulfit’ or ‘žveplov dioksid’

‘jajce’, ‘jajčne beljakovine’, ‘proizvod iz jajc’, ‘jajčni lizozim’ or ‘jajčni albumin’

‘mleko’, ‘proizvod iz mleka’, ‘mlečni kazein’ or ‘mlečne beljakovine’

Finnish

‘sulfiittia’, ’sulfiitteja’ or ’rikkidioksidia’

‘kananmunaa’, ‘kananmunaproteiinia’, ’kananmunatuotetta’, ‘lysotsyymiä (kananmunasta)’ or ’kananmunaalbumiinia’

‘maitoa’, ’maitotuotteita’, ‘kaseiinia (maidosta)’ or ‘maitoproteiinia’

Swedish

“sulfiter” or “svaveldioxid”

“ägg”, “äggprotein”, “äggprodukt”, “ägglysozym” or “äggalbumin”

“mjölk”, “mjölkprodukter”, “mjölkkasein” or “mjölkprotein”

Annex 3D – Pictograms (Sulphites/Egg/Milk)

Annex 4 –Sparkling Wine USA In fulfilling the mandatory class/type requirement, your wine must meet one of the following definitions in order to be labelled either “sparkling wine” or “carbonated grape wine”: Sparkling grape wine Includes: ‘‘sparkling wine,’’ ‘‘sparkling red wine’’ & ‘‘sparkling white wine’’

Grape wine made effervescent with carbon dioxide resulting solely from the fermentation of the wine within a closed container, tank or bottle.

Carbonated grape wine Includes: ‘‘carbonated wine,’’ ‘‘carbonated red wine,’’ & ‘‘carbonated white wine’’

Grape wine made effervescent with carbon dioxide other than that resulting solely from the secondary fermentation of the wine within a closed container, tank or bottle.

Note: wine which is artificially carbonated is subject to 10 cents less in excise tax per gallon than sparkling wine (see www.ttb.gov for more information).

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EU The new EU regulations provide the following definitions for the category of sparkling wine: SPARKLING WINE

QUALITY SPARKLING WINE

QUALITY AROMATIC SPARKLING WINE

AERATED SPARKLING WINE

SEMI-SPARKLING WINE

AERATED SEMISPARKLING WINE

Is obtained by first or second alcoholic fermentation from fresh grapes, grape must and/or wine

Is obtained by first or second alcoholic fermentation from fresh grapes, grape must and/or wine

Is obtained only by making use, when constituting the cuvée, of grape must or grape must in fermentation which are derived from specific wine grape varieties on a list to be drawn up in accordance with the procedure referred to in Article 113(2)

is obtained from wine without a protected designation of origin or a geographical indication

Is obtained from wine provided that such wine has a total alcoholic strength of not less than 9 % vol

Is obtained from wine

Which, when the container is opened, releases carbon dioxide derived exclusively from fermentation

Which, when the container is opened, releases carbon dioxide derived exclusively from fermentation

Has an excess pressure, due to carbon dioxide in solution, of not less than 3 bar when kept at a temperature of

Has an excess pressure, due to carbon dioxide in solution, of not less than 3 bar when kept at a temperature of

Has an excess pressure, due to carbon dioxide in solution, of not less than 3 bar when kept at a temperature of

Has an excess pressure, due to carbon dioxide in solution, of not less than 3 bar when kept at a temperature of

20 oC in closed containers; and

20 oC in closed containers; and

20 oC in closed containers; and

20 oC in closed containers

Has an excess pressure, due to endogenous carbon dioxide in solution of not less than 1 bar and not more than 2,5 bar when kept at a temperature of 20 oC in closed containers

Has an excess pressure of not less than 1 bar and not more than 2,5 bar when kept at a temperature of 20 oC in closed containers due to carbon dioxide in solution which has been wholly or partially added

The total alcoholic strength of the cuvées intended for their preparation shall not be less than 8,5 % vol

The total alcoholic strength of the cuvées intended for their preparation shall not be less than 9 % vol

The actual alcoholic strength may not be less than 6 % vol and the total alcoholic strength may not be less than 10 % vol

Has an actual alcoholic strength of not less than 7 % vol; and

Has an actual alcoholic strength of not less than 7 % vol. and a total alcoholic strength of not less than 9 % vol; and

Is put up in containers of 60 litres or less

Is put up in containers of 60 litres or less

Which, when the container is opened, releases carbon dioxide derived wholly or partially from an addition of that gas

When meeting the EU “category of grapevine product” requirement, producers must comply with these definitions.

If the wine is an aerated sparkling wine for the purposes of the definitions listed above, the label must state “obtained by adding carbon dioxide” or “obtained by adding carbon anhydride” underneath the product description (ie. “aerated sparkling wine”) in the same type and size.

In addition to the standard labelling requirements, all categories of sparkling wine (except for semi-sparkling and aerated semisparkling) must include: a) an indication of sugar content (see below); and b) the producer/vendor address rather than the mandatory bottler address.

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Sugar Content The sugar content may not differ by more than 3 grams per litre from what appears on the product label. The following terms and conditions of use apply to all categories of sparkling wine (excluding semi-sparkling and aerated semi-sparkling): Term

Conditions of use

brut, herb, briutas, bruts, tvrdé, bruto, zelo suho, bardzo wytrawne, брютzéro, natūralusis briutas, īsts bruts, přírodně tvrdé, popolnoma suho, dosaggio zero, брют натюр, brut natur

If its sugar content is less than 3 grams per litre; these terms may be used only for products to which no sugar has been added after the secondary fermentation.

extra brut, extra herb, ekstra briutas, ekstra brut, ekstra bruts, zvláště tvrdé, extra bruto, izredno suho, ekstra wytrawne, екстра брют

If its sugar content is between 0 and 6 grams per litre.

brut, herb, briutas, bruts, tvrdé, bruto, zelo suho, bardzo wytrawne, брют

If its sugar content is less than 12 grams per litre.

extra dry, extra trocken, extra seco, labai sausas, ekstra kuiv, ekstra sausais, különlegesen száraz, wytrawne, suho, zvláště suché, extra suché, екстра сухо, extra sec, ekstra tør

If its sugar content is between 12 and 17 grams per litre.

sec, trocken, secco, asciutto, dry, tør, ξηρός, seco, torr, kuiva, sausas, kuiv, sausais, száraz, półwytrawne, polsuho, suché, сухо

If its sugar content is between 17 and 32 grams per litre.

demi-sec, halbtrocken, abboccato, medium dry, halvtør, ημίξηρος, semi seco, meio seco, halvtorr, puolikuiva, pusiau sausas, poolkuiv, pussausais, félszáraz, półsłodkie, polsladko, polosuché, polosladké, полусухо

If its sugar content is between 32 and 50 grams per litre.

doux, mild, dolce, sweet, sød, γλυκός, dulce, doce, söt, makea, saldus, magus, édes, ħelu, słodkie, sladko, sladké, сладко, dulce, saldais

If its sugar content is greater than 50 grams per litre.

Terms Referring to Production Methods The following terms may on be used in the prescribed circumstances: Term

Conditions of use

“bottle fermented”

May only be used to describe wines with protected designations of origin or with a GI of a third country or quality sparkling wine if: (a) the product was made sparkling by a second alcoholic fermentation in the bottle; (b) the length of the production process, including ageing in the undertaking where the product was made, calculated from the start of the fermentation process designed to make the cuvée sparkling, has not been less than nine months; (c) the process of fermentation designed to make the cuvée sparkling and the presence of the cuvée on the lees lasted at least 90 days; and (d) the product was separated from the lees by filtering in accordance with the racking method or by disgorging.

“bottle-fermented by the traditional method” or “traditional method” or “classical method” or “classical traditional method”

May only be used to describe wines with protected designations of origin or with a GI of a third country or quality sparkling wine if it:

“crémant”

May only be used to describe white or “rosé” quality sparkling wines with protected designations of origin or with a geographical indication of a third country provided:

(a) was made sparkling by a second alcoholic fermentation in the bottle; (b) stayed without interruption in contact with the lees for at least nine months in the same undertaking from the time when the cuvée was constituted; (c) was separated from the lees by disgorging.

(a) the grapes were harvested manually; (b) it is made from must obtained by pressing whole or destemmed grapes. The quantity of must obtained shall not exceed 100 litres for every150 kg of grapes; (c) the maximum sulphur dioxide content does not exceed 150 mg/l; (d) the sugar content is less than 50 g/l; (e) complies with the requirements laid down in paragraph 4; and (f) the term “Crémant” must be indicated in combination with the name of the geographical unit underlying the demarcated area of the protected designation of origin or the a geographical indication of a third country in question.

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CHINA In fulfilling the mandatory product type requirement, your wine must meet one of the following definitions in order to use the terms “sparkling wine”, “carbonated wine” or “semi-sparkling”

Sparkling wine

Aerated wines with carbon dioxide (completely produced by natural fermentation) pressure greater than 0.35 MPa at 20oC (for bottles with a capacity of less than 250 ml and with carbon dioxide pressure greater than or equal to 0.3 MPa).

- Brut sparkling wines: sparkling wines with a sugar content of less than or equal to 12.0g/l (tolerable deviation: 3.0g/l). ­– Extra-dry sparkling wines: sparkling wines with a sugar content within the range of 12.1-17.0g/l (tolerable deviation: 3.0g/l).

– Dry sparkling wines: sparkling wines with a sugar content within the range of 17.1-32.0g/l (tolerable deviation: 3.0g/l) – Semi-dry sparkling wines: sparkling wines with a sugar content within the range of 32.1-50.0g/l.

– Sweet sparkling wines: sparkling wines with a sugar content greater than 50.0g/l.

Semi-sparkling wine

Aerated wines with carbon dioxide (completely caused by natural fermentation) pressure within the range of 0.05-0.34 MPa at 20oC.

Carbonated wine

Wines whose carbon dioxide is partially or completely added artificially, and which have similar physical properties to those of aerated wines.

© New Zealand Winegrowers February 2013

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