New Zealand Winegrowers Labelling Guide 30th Edition | February 2020

nzwine.com New Zealand Winegrowers Labelling Guide 30th Edition | February 2020

Disclaimer Information in this document is prepared by New Zealand Winegrowers for use by its members only. Material may not be published or reproduced without permission of New Zealand Winegrowers. This document represents our interpretation of the labelling regulations of various countries as at August 2019, 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, and its officers, employees and 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.

CHANGES IN THIS 29TH EDITION FEBRUARY 2020 Where substantive changes have been made since the last edition of the Labelling Guide, the text is shaded yellow.

UPDATES BETWEEN EDITIONS

For updates between editions we will include any new information on our website - please check here to see if there are any relevant changes.

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DESIGNING A WINE LABEL: THE BASICS 3 BRAZIL 31 NEW ZEALAND Brazilian labelling laws New Zealand labelling laws 5 Mandatory information 31 Mandatory Information 5 OTHER ASIAN COUNTRIES Optional information 6 Hong Kong 32 What else you should know 9 Thailand 32 Malaysia 32 AUSTRALIA Singapore 32 Australian labelling laws 11 India 33 Mandatory Information 11 Taiwan 33 Optional information 11 Philippines 33 EUROPEAN UNION (EU) Indonesia 33 EU labelling laws 12 ANNEX 1 Mandatory information 12 Appellations of origin for use in the USA 34 Optional information 14 ANNEX 2 UNITED STATES OF AMERICA Geographical Indications for use in Brazil 39 18 United States labelling laws Annex 3 Mandatory information 18 EU Allergen Declarations 40 19 Optional information Annex 3A 40 CANADA Permitted Languages/Translations (Sulphites) Canadian labelling laws 21 Annex 3B Mandatory information 21 Permitted Languages (Milk/Egg) 41 Optional information 22 Annex 3C Permitted Wording (Sulphites/Egg/Milk) 42 CHINA Chinese labelling laws 24 Annex 3D 43 Mandatory information 24 Pictograms (Sulphites/Egg/Milk) Optional information 25 Annex 4 Sparkling Wine 43 JAPAN USA 43 Japanese labelling laws 26 EU 44 Mandatory information 26 China 46 Optional information 26 Annex 5 SOUTH KOREA Representations of Origin 47 South Korea’s labelling laws 27 Annex 6 Mandatory information 27 Portman Group Guidance 50 Optional information 28

RUSSIA Russian labelling laws 29 Mandatory information 29 Optional Information 30

NEW ZEALAND WINEGROWERS’ LABELLING GUIDE 30TH EDITION I FEBRUARY 2020 1 INTRODUCTION

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: • 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 • This Labelling Guide which provides more detailed information and more market coverage. The digital version of this Labelling Guide can be downloaded from the member's section of www.nzwine.com under Sell / Compliance / Labelling.

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 Jeffrey Clarke on [email protected] or Silua Ettles on [email protected] for further assistance.

Cover image courtesy of Orinoco Vineyards

2 © New Zealand Winegrowers I nzwine.com 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)1 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:

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

Clean front label Legal back label (NZ/AUS)

JOHN’S WINERY 52 SYMONDS STREET John’s AUCKLAND New Zealand WIne MARLBOROUGH Contains approx 7.7 standard drinks SAUVIGNON BLANC 2013 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 • You can put any of the “single field of vision” (SFOV) information (see below) on the front as long as it is repeated in the correct legal form on the back label • If you are using this option in the USA, the front label needs to be designated the “Brand Label”

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.

JOHN’S WINERY John’s 52 SYMONDS STREET MARLBOROUGH AUCKLAND SAUVIGNON BLANC 2013 Contains approx 7.7 standard drinks

NEW ZEALAND WINE Contains Sulphites Produced with egg whites, traces may be present alc. 13% vol 750 ml SFOV front label Legal back label (NZ/AUS)

Some important points if you are using this option: • The front label is not so clean but it frees up space on the back label • If this option is used for the Canadian market, “New Zealand Wine” "Vin de Nouvelle-Zélande" must be presented in both English and French • 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

1 If your wine is exported in bulk to Australia, and labelled in Australia, it will need to meet the labelling requirements in Australia. This can be different to New Zealand.

NEW ZEALAND WINEGROWERS’ LABELLING GUIDE 30TH EDITION I FEBRUARY 2020 3 2. CHANGING THE BACK LABEL 4. FOR VINTAGE, VARIETY, GEOGRAPHIC INDICATION, THE MOST RESTRICTIVE RULES APPLY The back label needs to be changed for every market (except Australia which accepts legal NZ labels). For vintage, variety and geographic indication, the NZ rules are the baseline. You must always comply with these as a minimum. But if an Why? Because every country requires that the importer in their export market has more restrictive rules than NZ, you must follow territory is listed on the label to ensure traceability. Plus, most those rules as well as the NZ rules. countries will have their own unique requirements which aren’t compatible with other countries – like NZ’s standard drinks The only exception is a single grape variety statement in the USA requirement. where a 75% minimum is permitted rather than the NZ 85% minimum. Some people try to manage this by printing back labels with a blank space so they can add in different country requirements later. Others 5. SPECIAL WINES HAVE SPECIAL RULES have tried to list the importers for each different market on the same Sweet wines, sparkling wines, fortified wines, wines with high alcohol, label, but this takes up space and doesn’t get you into very many wines in non-standard packages – all of these may be subject to markets. special labelling rules. These may include: • special names that must be used on the label 3. SPECIAL LANGUAGE LABELS • additional mandatory information such as sweetness level Some markets like China, Japan and Russia require the label to be • different type size requirements presented in local characters. Canada requires some information The Labelling Matrix covers standard wines in a 750ml bottle only so to be presented in French and English. In these cases, it is best you should not rely on it when labelling special wines. You will need to produce a special label for the market. This should be done in to consult the Labelling Guide and possibly also the Winemaking consultation with your local distributor or importer to make sure you Practices Guide when labelling these products. 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.

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 and/or a pregnancy advisory logo or statement in the NZ market. • 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 Jeffrey Clarke on [email protected] or Silua Ettles on [email protected] if you have any questions.

4 © New Zealand Winegrowers I nzwine.com NEW ZEALAND

NEW ZEALAND LABELLING LAWS Alcohol by volume

The main laws governing the labelling of wine for sale in New Zealand A wine label must include an alcohol declaration (Standard 2.7.1). are the: The acceptable forms for the declaration are “XX ml/100g” or “XX ml/100 ml” or “X% alcohol by volume” or words or expressions • Food Act 2014 of the same or similar meaning: i.e. “X% vol” will suffice. • Australia New Zealand Food Standards Code Tolerances of the declared alcohol content from the actual alcohol • Food (Safety) Regulations 2002 content are: • Weights and Measures Regulations 1999 • fortified wine +/– 0.5% vol • Wine Act 2003 • wine and sparkling wine +/– 1.5% vol • Wine Regulations 2006 Net contents • Wine (Specifications) Notice 2006 A wine label must include a statement of the net contents, expressed • Fair Trading Act 1986 as litres, decilitres, centilitres or millilitres (e.g. 750 ml). This • Sale and Supply of Alcohol Act 2012 statement should be: Copies can be found at either the Government’s legislation website • at least 2mm in height www.legislation.govt.nz or the Ministry for Primary Industries’ wine • placed in a prominent position in close proximity to the name of information portal www.foodsafety.govt.nz the product (front or back label)

MANDATORY INFORMATION • in a colour that contrasts distinctly with the background Each item in this section is mandatory. (R.79, Weight & Measures Regs 1999)

Presentation And Placement • permitted abbreviations are ml or mL for millilitres and l or L for litres (but not ML which denotes megalitres). With the exception of “net contents”, there are no minimum type size or placement requirements for any of these mandatory Producer items, although they must be in English and presented legibly and A wine label must include the name and business address in New prominently such as to afford a distinct contrast to the background Zealand or Australia of the supplier (Standard 1.2.2). (Standard 1.2.9). The “supplier” may be the producing winery, packer, vendor or Product name importer. The address must be a physical address and may not just A wine label must include a name or description that indicates the be a rural address eg. "RD2" or a website address. Note that the true nature of the food (Standard 1.2.2). For wine, this can be: person named on the label is presumed to be responsible for the • the word “wine” product and will be legally liable for that product under the Food Act • the type of wine (e.g. “sparkling wine”, “white wine” etc) 1981/2014.

• a variety name Sulphite declaration • a generic name such as Port 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: Country of origin “contains preservative 220”, “contains sulphites”, or “contains A wine label must include a statement indicating the country of sulphur dioxide”. This is not a “warning statement” in terms of the origin (e.g. “New Zealand wine”, “Product of New Zealand”) (r. 7 Food Standards Code, and the type size requirements therefore do of the Wine Regulations 2006). If any of the grapes, grape juice, not apply. concentrated grape juice or spirit used in a wine originates in another Allergen declaration country, then that must also be included on the label - i.e. you cannot use imported concentrated grape juice unless you are prepared to A wine label must include an allergen declaration if milk, milk acknowledge it in the country of origin statement. See the note below products, egg, egg products, fish products (except for isinglass) 1 on Representations of Origin. or other allergens are “present” in the wine (Standard 1.2.3). Isinglass is exempted from this requirement. The form of the labelling requirement is not specified in legislation.

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

NEW ZEALAND WINEGROWERS’ LABELLING GUIDE 30TH EDITION I FEBRUARY 2020 5 In some countries an analytical laboratory residue test result of particular wine then there is no need to include a lot number, as the ‘not detected’ (using a method of detection with a 0.25ppm limit lot’s identification is self-defined. of detection) is considered a confirmation that allergens are “not present”, and do not need to be labelled. OPTIONAL INFORMATION Recently, MPI has provided written clarification of how it intends to General provisions enforce Standard 1.2.3. In addition to the mandatory items, there are also some general MPI has stated that if processing aids containing allergens (other provisions it is necessary to note. Wine labels cannot: than isinglass) have been used in production, all wine labels for the • bear health claims New Zealand market should include an allergen declaration using one • encourage or be likely to encourage excessive consumption of the formulations below. • be aimed at or be likely to have special appeal for minors • “Fining agent: [milk/egg] products.” • make representations as to being low in alcohol or non- • “Produced with [milk/egg] products. Traces may remain.” intoxicating or • “[Milk/Egg] products have been used as a fining agent in the • be false or liable to mislead or deceive consumers manufacture of this wine. Traces may remain.” The Sale and Supply of Alcohol Act 2012 includes a number of • “[Milk/Egg] products have been used to purify this wine, in restrictions on advertising and promotion of alcoholic beverages accordance with traditional winemaking techniques. Traces may that may impact on wine labelling. The Health Promotion Agency has remain.” produced guidance on these requirements that can be found online The following additional forms of declaration were developed by the here. Wine Australia in consultation with Food Standards Australia New The Advertising Standards Authority’s “Code for Advertising and Zealand. If exporting to Australia, it may be preferable to use these Promotion of Alcohol” and the Fair Trading Act provide further forms: guidance in this regard. • “Produced with casein (milk product)” Fair Trading Act 1986 • “Contains/produced with milk product” All information on a wine label (as well as any other material used to • “Produced with casein (milk product). Traces may remain” present or describe a wine) is subject to the Fair Trading Act 1986, • “Produced with milk products. Traces may remain” which prohibits misleading or deceptive conduct in trade, conduct that is liable to mislead in respect of goods, and false or misleading Standard drinks representations as to the quality, grade, composition, style, place of A wine label must include a standard drinks declaration (Standard origin or nature of products. The New Zealand Winegrowers 2.7.1). A standard drink is the amount of wine containing 10 grams Legal Guide provides useful guidance in relation to the Fair Trading of ethanol measured at 20° C. Act. Note that misleading or deceptive conduct or representations If the product contains: relating to goods supplied from New Zealand to China will be an • less than 10 standard drinks, the statement of the number of offence under the Fair Trading Act and may authorise a search standard drinks must be accurate to 1 decimal place warrant being issued in New Zealand. • more than 10 standard drinks then the statement of the number Under the Fair Trading Act it is also an offence to make an unsubstantiated of standard drinks must be accurate to the nearest whole representation in trade. A representation is unsubstantiated if the person number making the representation does not, when the representation is made, The form of the standard drink statement is: “contains approx. x.x have reasonable grounds for the representation, irrespective of whether standard drinks”. The word ‘approximately’ may be spelt in full if desired. the representation is false or misleading. This could include such matters Standard drinks can be calculated on the labelled alcoholic content of as a representation of organic or sustainable status for products that the wine. The formula for calculating the number of standard drinks is: are not certified as having such status. Note that representations that a 0.789 x the alcohol content x the volume of the container (in reasonable person would not expect to be substantiated are exempted litres). from this requirement.

So for a wine with a labelled alcohol content of 12% in a 750 ml bottle Grape variety, vintage and geographical indication: the 85% rule the formula is: 0.789 x 12 x 0.75 = 7.1. From vintage 2007, the following rules for label claims covering grape variety, vintage and the area where the grapes were grown (other Lot identification than the country of origin) apply: 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 • single variety, vintage or area: at least 85% from the stated variety, vintage or area. For example, if a label says the wine

6 © New Zealand Winegrowers I nzwine.com is ‘2007’, at least 85% of that wine must be from the 2007 Pinot vintage MPI has advised that the term Pinot is an acceptable synonym for • blends: at least 85% of the blend must be from the stated Pinot Noir. However the term Pinot could be considered misleading to varieties, vintages or areas. For example, if the wine label says consumers if used for a blend of less than 85% Pinot Noir and Pinot ‘Chardonnay Chenin Blanc, then at least 85% of that wine must Gris, or for a Pinot Gris. have been made from Chardonnay and Chenin Blanc grapes • combination claims: the combination referred to must be at least Cabernet 85% of that wine. For example, if a label states that the wine is MPI has advised that: a ‘2008 Marlborough Pinot Noir’, then 85% of the wine must • it is acceptable to use “Cabernet” as a synonym for Cabernet be from Pinot Noir grapes grown in Marlborough in the 2008 Sauvignon but not for Cabernet Franc or a combination of those vintage two varieties • where a label refers to more than one grape variety, more than • if Cabernet Franc is part of a wine label claim about grape one vintage, or more than one geographic area, these must be varieties, it must be named in full presented in descending order of proportion in the blend. Using the ‘Chardonnay Chenin Blanc’ example above, as well needing Sauvignon Gris to meet the 85% rule, there must be a greater proportion of “Sauvignon Gris” is a statement regarding a single grape variety (not Chardonnay than Chenin Blanc in the blend a blend of Sauvignon Blanc and Pinot Gris). The 85% rule therefore • a label must not include a claim about grape variety, vintage or applies so that if a wine is labelled “Sauvignon Gris”, then at least area of origin if that wine contains a greater percentage of wine 85% of that wine must have been made from Sauvignon Gris grapes. from another grape variety, vintage or area of origin that is not referred to by that label. For example, a wine that contains 75% Moscato Cabernet Sauvignon, 15% Pinotage and 10% Merlot could be MPI has advised that “Moscato” (or “Muscato”) is a varietal referred to as a ‘Cabernet Pinotage’ or a ‘Cabernet Pinotage descriptor and can therefore only be used where at least 85% of the Merlot’ but not a ‘Cabernet Merlot’ wine consists of “Muscat” varieties. If any further differentiation of • cultures of micro-organisms used to make wine may be the Moscato variety is given (e.g. Muscat of Alexandria), then at least excluded from the minimum content calculations (up to a 85% of that wine must have been made from the named variety.

maximum of 50ml/L) as can brandy or other spirit used for 'Single vineyard' and similar statements fortifying wine Some wine labels bear statements that create the impression that • the use of concentrated grape juice as a sweetener is excluded the wine is made from grapes that are exclusively grown in a specific from the 85% region, variety, vintage calculations. This exclusion vineyard (e.g. “single vineyard” followed by a vineyard name) or does not apply to the country of origin statement produced in a particular way (e.g. "hand picked"). Where such terms • an exemption applies to wines made from or containing wine are used, NZW’s view is that the grapes should be exclusively sourced from the 2006 vintage. Contact NZW if you require further from the named vineyard (100%) or produced in the specified way in information order to avoid creating a misleading impression. The Geographical Indications (Wine and Spirits) Registration Act 2006 is now in force. This does not change any of the above requirements Exports regarding grape variety, vintage and geographical indication. The 85% rule is a benchmark minimum content for all New Zealand wine, whether sold domestically or exported. This means that, in Representations of origin principle, all wine made from 2007 onwards and exported from New Features of a label such as a geographical brand name, Maori Zealand must be made in accordance with the 85% rule above, imagery/wording, business description/address or pictorial subject to the following: representations of a geographic location can combine to imply the • if the overseas market has a stricter labelling requirement, the New Zealand or regional origin of a product. Where the combined overseas market requirement must be complied with. effect of a product’s packaging implies a specific geographical origin • if the overseas market has a less strict requirement and MPI which is not accurate in terms of the product’s composition, wineries has given specific permission for exporters to use the less should take steps to ensure that the correct origin of the product is strict requirement applying in that market, then the less strict immediately obvious to any prospective purchaser or risk breaching requirement is available to exporters. the Fair Trading Act. Annex 5 contains a more detailed discussion of the use of representations of origin.

NEW ZEALAND WINEGROWERS’ LABELLING GUIDE 30TH EDITION I FEBRUARY 2020 7 Trans Tasman Mutual Recognition claim on the label of an alcoholic beverage containing more than The effect of the Trans Tasman Mutual Recognition Agreement 1.15% alcohol by volume. (TTMRA) and the Australian New Zealand Closer Economic Relations A nutrition content claim is defined as a claim that is made about: Trade Agreement (ANZCERTA) also means that, in general, a wine • the presence or absence of energy (eg. calories or kj), a that can be legally sold in New Zealand can also be sold in Australia. biologically active substance, dietary fibre, minerals, potassium, However, wine that has been exported in bulk to Australia and bottled protein, carbohydrate, fat, salt, sodium or vitamins; or in Australia is required to meet Australian requirements. If it is • glycaemic index or glycaemic load, bottled and labelled in New Zealand and then exported to Australia, compliance with New Zealand regulations and the Wine Act 2003 will that does not refer to the presence of alcohol and is not a health ensure it is able to be sold in Australia. claim. A “gluten free” claim counts as a nutrition content claim. There are no stock-in-trade provisions, so we recommend that all new Environmental, sustainability and organic claims labels comply with this requirement. The Commerce Commission requires that “Businesses making Vegetarian and Vegan claims environmental claims - including statements about sustainability, recycling, carbon neutrality, energy efficiency, use of natural products NZ does not have specific regulations that govern the use of the or impact on animals and the natural environment - should ensure terms vegan and vegetarian on a wine label. those claims are accurate, scientifically sound and substantiated.” The overarching requirements of the Fair Trading Act apply, so this As above, such substantiation is now a requirement under the Fair means if you make a vegan or vegetarian statement on your wine Trading Act. New Zealand Winegrowers recommendation is that all label you should: such claims should be substantiated by current full certification to an • Ensure you have reasonable grounds to make the claim; appropriate third party scheme. • only rely on facts, figures and credible sources (when it comes New Zealand Winegrowers provides detailed guidance on the use of to ensuring that your product is actually vegan/vegetarian) environmental, sustainability and organic claims in the New Zealand • keep and be able to show documentation to support your claim. Winegrowers Code of Practice for Environmental Claims available at There are a number of vegan and vegetarian societies that have a www.nzwine.com. registered trademark that you can register and pay to use. In order to use the Sustainable Winegrowing New Zealand (SWNZ) logo, permission must be granted by the SWNZ Business Manager. Nutrition content claims Permission is only granted under the following circumstances and is at If you want to make a nutrition content claim, use the flow chart the discretion of SWNZ: below to check whether it is permitted. If permitted, be sure • the wine company registered with NZW must be a SWNZ Tier 3 to follow the relevant detailed requirements. Note that this is a member summary. A complete guide is available at • the wine must be made from 100% accredited vineyard grapes www.foodstandards.govt.nz • the wine must be wholly produced in accredited winery facilities • the SWNZ logo rules are fully complied with For further information please contact [email protected].

Health Claims Health claims are not permitted on the label of an alcoholic beverage. A health claim is a claim which states, suggests or implies that a food or property of food has, or may have, a health effect - i.e an effect on the human body, including an effect on one or more of the following: a biochemical, physiological, functional process or outcome, growth and development, physical performance, mental performance and a disease, disorder or condition. This would include, for example, claims that certain properties or components of wine have protective effects on heart health. MPI have guidance on the use of such claims on their website: www.foodsafety.govt.nz

Nutrition content It is no longer permitted to make a nutrition content claim other than an energy content (calorie), carbohydrate content or gluten content

8 © New Zealand Winegrowers I nzwine.com Low/Lower Alcohol Claims Is the claim about: STOP! N Energy, Carbohydrates you cannot make Have you claimed Y or Gluten? the claim Must be <1.15% Alc Y 'Low Alcohol' N

Have you made a Y Y Gluten Free claim? Have you claimed Must be <2.5% Alc 'light' or 'lite' N N Include a Nutritional Information panel

Have you claimed Y We recommend you identify 'reduced', 'lower', a reference product Is it a comparative N 'lighter' in alcohol claim? e.g. 'lighter in energy, lower in carbs' Health advisory information/Pregnancy labelling Y Food Standards Australia New Zealand (FSANZ) has just announced Mention the reference product. that mandatory pregnancy labelling will be required within You can make these Reduction must be at least 25% approximately the next two years. The guidance below will be replaced statements or claims lower than reference. once final rules have been gazetted. NZW recommends that members include a pregnancy health advisory statement on the labels of all Permitted energy content or carboydrate claims wine sold in New Zealand. This may take the form of either a written In order to make an energy or carbohydrate content claim under message indicating that the safest option for pregnant women is Standard 1.2.7 the following elements must be included on the label: not to drink or the pregnancy advisory logo. Mandatory pregnancy 1. a nutritional information panel (NIP) (standard 1.2.8); labelling is likely to be imposed within the next year. NZW will keep members updated with any changes. Wineries can download this logo 2. if a comparative claim is made (e.g. ‘reduced calorie’, 'lighter', via nzwine.com/members and search 'Pregnacy Labelling'. ‘reduced carbohydrate’ or similar terms) the claim must include: a) the identity of the reference food and b) the difference between the amount of the property of food in the claimed food and the reference food. For example: Cheers! “Reduced calorie wine - at least 25% less calories compared Wineries are also encouraged to use the Cheers! logo as a way of to the standard [X Brand] Sauvignon Blanc 2013.” driving consumers towards the www.cheers.org.nz website where 3. terms such as “reduced”, “lighter” or their synonyms will only useful information on safe and responsible drinking can be found. be permitted where the reduction in content is at least 25% To use the Cheers! logo please visit nzwine.com/members and compared to the reference product. search ‘Cheers!’. A NIP is not required for a gluten free claim.

Lower alcohol claims The Australia New Zealand Food Standards Code prohibits any product containing more than 1.15% alcohol from being represented Ice wine as a "low" alcohol beverage. In addition, the Advertising Standards New Zealand is a signatory to the World Wine Trade Group Agreement Authority Code for Advertising and Promotion of Alcohol defines “light” on Requirements for Labelling, which contains provisions regarding (or “lite”) as containing a maximum of 2.5% alcohol by volume. the use of the term “Ice Wine” / “Icewine”. Statements about alcohol levels such as “low alcohol”, “lower in The Labelling Agreement defines “Ice Wine” / “Icewine” as a product alcohol”, “reduced alcohol” or “lighter in alcohol” do not count as made from grapes that have been naturally frozen on the vine. Once “nutrition content claims" so are not controlled by the restrictions the agreement is fully implemented, only wines that comply with this described in the section and flowchart above. However, producers may definition will be permitted for export to USA, Australia, Canada, Chile voluntarily choose to follow a similar approach by ensuring that they and Argentina. However, wines that do not comply with this definition include the identity of the reference product and the difference between (i.e. wines made from grapes or wine that have been artificially the alcohol content in the claimed wine and the reference wine. refrigerated) may continue to be sold in New Zealand.

NEW ZEALAND WINEGROWERS’ LABELLING GUIDE 30TH EDITION I FEBRUARY 2020 9 If the Trans-Pacific Partnership Agreement enters into force, New Note: These guidelines apply to New Zealand only. Different Zealand has agreed to apply this definition to all New Zealand wine countries’ retailers or importers (e.g. Canada’s LCBO Product Packaging Standards) may have their own requirements. labelled as "Ice Wine"/ "Icewine". The USA already has rules in place dealing with “Ice Wine” / “Icewine” Barcodes pursuant to which it will not permit use of the term “Ice Wine” / There is no legal requirement to include a barcode on your label. “Icewine” for wines made from grapes or wine that have been Barcodes are usually required by retailers. artificially refrigerated. However, it will permit use of the term “Ice” for A barcode is essentially a method for encoding in machine-readable such wines as part of a brand – e.g. “Freddy’s Ice”. format a unique number for a product which is called a Global Trade The Labelling Agreement does not apply to exports to non-signatory Item Number (GTIN). countries. However, some non-signatory countries have their own The EAN-13 barcode (encoding a 13 digit GTIN) is the barcode rules regarding the use of “Ice Wine” / “Icewine”, including China and used in New Zealand, Australia, Asia and Europe and is generally the European Union. acceptable worldwide for all retail/consumer items (e.g. individual

Batch consistency 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 Good winemaking practice suggests that where a wine has been GTIN encoded into a barcode called a UPC-A. Most retailers in North produced and bottled in a number of batches, those batches should America after 1 January 2005 should accept EAN-13 barcodes, but be consistent in terms of organoleptic characteristics and chemical some still require a UPC-A. profile (allowing for testing tolerances and the effects of maturation). Where batches of wine are produced that are not representative Some retailers and wholesalers require special barcodes on cases of other wine sold under the same label in a single market, we and pallets of wine, either for automated scanning on conveyor belts recommend that these be distinguished through their labelling. (an ITF-14 barcode encoding a 14-digit GTIN) or for traceability For example, early batches of wine for immediate release could be purposes (an EAN-128 barcode that can encode details such as labelled as “Early Release”, “First Release” or similar. batch, processing date, Global Location Number of the vineyard etc). It is vital that before printing your labels that you check that your WHAT ELSE YOU SHOULD KNOW barcode scans easily. A ‘pass’ on the international standard for barcode quality – a ‘verification test’ - is often a trade requirement. Cleanskins For further information and assistance contact Wines sold as “cleanskins” by the bottle or the carton, still need to GS1 New Zealand at www.gs1nz.org or 04-494 1050. comply with labelling regulations when they are sold at retail or in the on trade. Wines over 15% alcohol If cleanskin wines are sold at wholesale, they must still bear the There is no legal maximum alcohol limit for table wine or fortified wine product name (e.g. “wine”, “Cabernet Sauvignon”, “Port”), lot in New Zealand. However, fortified wine over 15% alcohol may not be identification and name and address of the supplier on the bottle sold in a supermarket, but may be sold in other off-licensed premises. or carton. Further information on mandatory labelling requirements must be provided to the wholesale purchaser on request. 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 Cartons table (i.e. unfortified) wine is over 14% alcohol it does not qualify Outer packaging does not need to be labelled or marked if it is: for the higher excise rate. It is the addition of fortifying spirit, rather than the alcohol level, that makes a wine qualify for the • for the purposes of transportation and distribution only; and higher excise rate. • of a kind intended to be removed before the food is offered for retail sale; and • 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.

10 © New Zealand Winegrowers I nzwine.com AUSTRALIA

AUSTRALIAN LABELLING LAWS Please note that it is illegal to use protected names [other than The Australia New Zealand Food Standards Code (Code) applies to in compliance with the prescribed conditions] in the description both Australia and New Zealand. New Zealand wines bottled in New and presentation of wine in any context whatsoever, even in an otherwise true statement in textual form on a back label (eg. Zealand labelled in accordance with the Code will comply for the ‘this wine is made from a typical Bordeaux blend of grapes’, or Australian market as regards mandatory information. The effect of ‘Marsanne is a native variety of the Rhone Valley’, or ‘my family the Trans Tasman Mutual Recognition Arrangement (TTMRA) and the have grown grapes in Chianti for generations’, or ‘this wine is from Australia New Zealand Closer Economic Relations Trade Agreement vineyards near the famous Barossa Valley’ or ‘this wine is equal to (ANZCERTA) also means that, in general, a wine that can be legally a top Hunter Semillon’). Protected Names are only protected when sold in New Zealand can also be sold in Australia. 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 MANDATORY INFORMATION protected. To clarify the boundaries for use of Protected Names, A label designed in compliance with New Zealand labelling laws can you could, in say promotional material, use Protected Names to describe family history, or discuss generally the wine styles also be used for wines exported to Australia. you make, or comparing your climate conditions with European regions etc but whenever you are describing a particular wine then OPTIONAL INFORMATION Protected Names cannot be used in any context. Again, the situation is generally the same as applies in New Zealand, although care is needed in relation to geographical indications. Note that this protection can have unintended consequences. AGWA Protected Geographical Indications (GI) recently issued guidance that the term “orange wine” should not be used as it conflicts with the Australian GI “Orange”. 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. 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 Grape and Wine Authority (AGWA) in relation to using protection names to describe a wine:

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

NEW ZEALAND WINEGROWERS’ LABELLING GUIDE 30TH EDITION I FEBRUARY 2020 11 EUROPEAN UNION (EU) •

EU LABELLING LAWS All Member States of the European Union share the same general wine labelling laws. In some cases, different authorities in various countries In every case, wines must comply with the definition that applies to will have different interpretations of those laws, or additional national each category (see Annex 4 for more information on sparkling wine). requirements. The category of grapevine product must appear in the same field The main laws are Regulation 934 of 2019, 1308 of 2013 (the core of vision as the country of origin, the net contents, and the alcohol EU agriculture law) and Regulation 607 of 2009 (the wine labelling declaration. law). There are a number of other laws that touch on aspects of labelling, such as fair trading, allergen declarations and organics. Sweet and high alcohol wines Note that this guidance deals specifically with the requirement for A wine will qualify as “normal” wine if it meets the following criteria: a 750ml bottle of still wine. Other types of wines (e.g. sparkling, • 8.5% or more actual alcohol fortified) may be subject to a different set of rules that are not • up to 15% total (i.e. actual + potential) alcohol covered here. If you would like assistance with labelling for such • no enrichment (including chaptalisation) wines, please contact us. The NZW members website is being updated regularly on export matters to the UK following the exit of UK from • no sweetening or sugar adjustment the EU on 31 January 2020. There is a transition period until 31 Outside those parameters, the wine will need to come within one of December 2020 to allow for a new Free Trade Agreement to be the following special categories: “wine of overripe grapes” or “wine negotiated during this time there will be no change to the rules of raisined grapes” and be labelled as such. The definitions are as covering trade from NZ to the UK/EU. Click here to find out the follows: latest updates. Wine from overripe grapes: MANDATORY INFORMATION • is produced without enrichment Presentation and placement • has a natural alcoholic strength of more than 15% vol All compulsory statements must be easily readable, in indelible • has a total alcoholic strength of no less than 15 % vol. and an characters large enough to stand out against the ground on which actual alcoholic strength of not less than 12% vol they are printed and clearly distinguishable from all other content of • no maximum actual alcohol % vol. the labelling.

The following information must appear in a single field of vision clearly Wine from raisined grapes: distinguishable from all other content and printed horizontally: • is produced without enrichment, from grapes left in the sun or • category of grapevine product (i.e. product name) shade for partial dehydration • country of origin (what the EU calls “indication of provenance”) • has a natural alcoholic strength of at least 16% vol (or 272 • net contents; and grams sugar / litre) • alcohol declaration • has a total alcoholic strength of at least 16 % vol. and an actual Except where otherwise noted below, all mandatory information must alcoholic strength of at least 9% vol be at least 1.2 mm in height, based on the height of a lowercase • no maximum actual alcohol % letter ‘x’ of the font you are using. If a geographic indication is used, We recommend that all wines with more than 15% total alcohol this must also appear in the same field of vision. use one of these designations as appropriate on the label to avoid You can repeat mandatory information in other places on the label. problems in the market.

Product name Country of origin All imported wine labels must bear the “category of grapevine All imported wines must bear an “indication of provenance” on the product” (i.e. product name): label. For New Zealand wine, the indication of provenance will be “New • for still, unfortified wines of less than 15% total alcohol, the Zealand”. category of grapevine product will simply be “wine” The category of grapevine product can appear together with the • fortified wines must use the designation “liqueur wine” and indication of provenance as “New Zealand Wine” (recommended) or wines over 15% total alcohol must use the designation “wine of “Wine of New Zealand”. Alternatively it can appear as “Product of overripe grapes” or ”wine of raisined grapes” New Zealand”, “Produced in New Zealand” or equivalent expressions. • sparkling wines may use the categories: sparkling wine, The indication of provenance must appear in the same field of vision quality sparkling wine, quality aromatic sparkling wine, aerated as the category of grapevine product, the net contents, and the sparkling wine, semi-sparkling wine or aerated semi-sparkling alcohol declaration.

12 © New Zealand Winegrowers I nzwine.com Alcohol by volume Sulphite declaration All imported wine labels must bear a statement of alcoholic content. All imported wines must bear a sulphite declaration if they contain This must be expressed as x% vol. in whole or half units (e.g. 12% more than 10 mg/l of sulphur dioxide. The form of the declaration vol., 12.5% vol.) It may be preceded by the words “actual alcoholic is "contains sulphites" or "contains sulphur dioxide" in the approved strength”, “actual alcohol” or “alc”, e.g. x% vol., actual alcoholic language of the market in which the wine is sold. American spellings strength x% vol., actual alcohol x% vol., alc x% vol. The minimum (“sulfites”, “sulphur”) are permitted. The declaration can appear on print size is 3mm for a 750ml bottle. The tolerance for the alcohol any label. statement is +/- 0.5%vol. Many EU Member States require that the sulphite declaration is in The alcohol statement must appear in the same field of vision as the the national language or languages. This will present difficulties for category of grapevine product, the net contents, and the country of origin. wineries exporting to multiple EU markets, as it may be necessary to have different sulphite declarations for each market. A list of the Net contents relevant languages is attached at Annex 3B. All imported wine labels must bear the net contents. This must be The following pictogram may be used on the label in addition to the expressed in litres, centilitres or millilitres, and must be at least 4mm written form of the sulphite declaration. However, it is not compulsory. 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, 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 Allergen declaration or legal person or group of such persons established within the Labels for wines exported to the EU must include an allergen Community assuming responsibility for bringing into circulation non- declaration if: Community goods. • they are produced from grapes grown in the 2012 vintage or The importer details may appear on any label. subsequent vintages; and The UK Food Standards Agecncy (FSA) has previously advised that, • they contain traces of milk or egg products (see below for for wine with a UK importer, only the UK importer address should further information); and appear on the label. Other EU states have not imposed this restriction. • they are labelled in New Zealand on or after 1 July 2012 (or in However, should Brexit happen, a UK importer statement will no the case of bulk wine, they have entered the EU market after longer be allowed for imports to the EU market; an EU importer that date) statement will be required (there is no grace period in the EU). As noted above, it is only necessary to label wines if they contain The UK Government has issued guidance indicating there will be a traces of milk or egg products. The EU has specified that methods transition period until December 2020 for goods placed on the UK of detection recommended by the International Vine and Wine market after Brexit. During that period: Organisation (OIV) may be used. This requires an ELISA test kit that • if Food Business Operator (FBO) is based in the UK, then a UK can test to the limit of detection of 0.25 mg/L. You should contact address must be included; however, your laboratory for further information. • if the FBO is not based in the UK, then the address of the The declaration can appear on any label. The form of the declaration Importer bringing the food into the UK is permitted. Accordingly, is “contains milk” or “contains egg” in the approved language of labels with an EU importer address, that are initially imported the market in which the wine is sold. If multiple allergens are present into the EU before being sent to the UK should be acceptable for (including sulphites) you do not need to repeat the word “contains”. both the EU and UK markets. Lists of the relevant languages, permitted wording and translations If the same wine is placed on the market in more than one country, are attached at Annex 3. the importer in each country may need to be included on the label.

NEW ZEALAND WINEGROWERS’ LABELLING GUIDE 30TH EDITION I FEBRUARY 2020 13 You can also choose to use one of the official pictograms in Annex Variety 3D. This is optional but if you choose to use them they must still A grape variety may be used on the label of a wine exported to the be accompanied with the “contains milk/egg” statements. Allergen EU. Only varieties that are on the list of approved varieties submitted declarations for fish products are not required in the EU. 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 Lot identification are developing a new variety, we recommend that you check with us All imported wine labels must bear a lot number on a label or on the whether the variety is listed or not. bottle. This should appear as “L” followed by an alphanumeric code New rules seek to prevent or limit New Zealand producers using some (e.g. “L1234” or “L123AB”). Italian grape variety names including: Barbera, Freisa, Montepulciano,

Health advisory (France only) Nebbiolo, Primitivo, Sangiovese, Verdicchio and Vernaccia. Whether of not these restrictions are legitimate, to avoid challenge in market, French law requires all wine to bear the following health message and/ appropriate synonyms may be used. or pictogram: « La consommation de boissons alcoolisées pendant la grossesse, The minimum content for a single grape variety is 85%. Two or même en faible quantité, peut avoir des conséquences graves sur more varieties may be used on a label, however the wine must be la santé de l’enfant. » 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 The text of the message means: “The consumption of alcoholic Cabernet Sauvignon). beverages during pregnancy, even in small quantities, can have Note that the UK Wine Standards has expressed the view that the serious effects on the health of the child.” grape variety name must be clearly distinguishable from other The health message should be written in contrasting type, so as to be information, meaning that vintage dates or brand names may not be visible, readable, clearly comprehensible, and indelible. It must not be permitted on the same line close to the variety name. obscured or interrupted by other indications or images. It does not need to be in any particular colour or size. Vintage The health message must appear in the same field of vision as the A vintage date may be used on the label of a wine that bears a alcohol declaration. This has implications for how labels are designed geographical indication. The minimum content for a vintage date is for multiple markets that include France. If you wish to avoid having to 85%. Where a single grape variety appears in conjunction with a put the health message on your front label, you will need to place all vintage, then the 85% rule applies concurrently (e.g. if a wine label of your “single field of vision” information (which includes the alcohol says 2004 Cabernet Sauvignon, then it must contain at least 85% declaration) on the back label. You may still repeat the “single field of 2004 Cabernet Sauvignon). vision” information on the front label if desired. Production methods The UK has confirmed that this warning/pictogram is acceptable in their market, but we have not received such confirmation from other References to production methods are generally permitted. However, markets. We have received advice that the USTTB has indicated that certain references, including “bottle fermented”, references to oak the French warning/pictogram is not acceptable in the USA. aging and “rosé” are subject to special rules.

Bottle fermented/ traditional method OPTIONAL INFORMATION Specific rules apply to the use of the term “bottle fermented”, Note that NZ rules (including, for example, the 85% rule) represent a including a requirement that the wine undergoes secondary baseline that must be met in addition to EU standards. fermentation in a bottle of at least 90 days. More stringent rules apply Geographical indication to wines described as “traditional method”, “méthode traditionnelle”, To use a geographic indication, the wine must be at least 85% from “classical method”, “crémant” etc. See Annex 4 to this guide for the stated region. No more than one geographical indication may be more information. 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).

14 © New Zealand Winegrowers I nzwine.com Traditional terms Rosé “Traditional terms” are terms that the EU considers should be used Under EU rules it is not permitted to blend red wine with a white exclusively with EU protected geographical indications. Exporters wine and call it a rosé unless both wines have either a Protected should be aware that a number of “traditional terms” are now Designation of Origin (PDO) or Protected Geogrpahical Indication protected in the EU in their specified language. Key “traditional terms” (PGI). On the other hand, OIV rules do permit blending of different of relevance to New Zealand exporters (protected in the bracketed wines without any limitation on the production of rosé wine. languages) include: NZ Geographical Indications do not meet the requirements of a PDO AUSLESE (GER); SPATLESE (GER) or PGI as defined by the European Commission. Our interpretation CREAM (EN) VILLAGES (FR) is that wines blended from red and white varieties may be produced PREMIUM (CZ) CLASSIC (GER, EN) for the EU market. However, it is unclear whether these wines are VENDAGES TARDIVES (FR) NOBLE (SP) permitted to be called a rosé if exported to the EU. CHATEAU (FR) SUPERIOR (POR, SP) Rosé wines produced from red grapes (e.g. by the saignée method) DOMAINE (FR) VINTAGE (EN) can be labelled “Rosé”. Addition of red wine to white wine for the RESERVE (GER) CLARET (FR) production of sparkling rosé wine is permitted. TAWNY (EN) RUBY (EN) CLOS (FR) SUR LIE (FR) Sweetness levels FINE (IT) Sparkling wines must bear an indication of sugar content (e.g. brut, Note that Ruby, Tawny and Vintage are only protected sec etc). See Annex 4 to this guide for more information. For other in relation to fortified wines. wines, an indication of sweetness is optional but if it is used the wine Traditional terms are only protected in the language and for the must fall within the appropriate sweetness range as below. categories of grapevine products specified in the regulation. This is generally taken to mean that, for example, “Reserve” is only protected Dry, sec, etc. If its sugar content does not exceed: when used on a wine label in the German language. However, if the 4 grams per litre, or use of such a term on an NZ wine label in the EU could be confused 9 grams per litre, provided that with its use as an EU traditional term then that could also potentially the total acidity expressed as create a problem. Enforcement of the rules is at the discretion of the grams of tartaric acid per litre is Member States in which potentially infringing product is sold. not more than 2 grams below the residual sugar content. The terms “classic” and “cream” have recently been protected for use in English by the USA. This means that a use of these terms on the label of a New Zealand wine in the EU could potentially be in Medium dry, demi-sec etc If its sugar content exceeds the maximum set out above but does breach of EU regulations. not exceed: 12 grams per litre, or Oak aging 18 grams per litre, provided that The following terms are currently the only terms permitted to describe the total acidity expressed as wine that has been fermented, matured or aged in a wood container. grams of tartaric acid per litre is not more than 10 grams below BARREL BARREL MATURED BARREL AGED the residual sugar content. FERMENTED […]-cask fermented […]-cask matured […]-cask aged Medium, medium sweet, If its sugar content is higher than [indicate the type of [indicate the type of [indicate the type of moelleux etc. the maximum set out above but wood] wood] wood] not more than 45 grams per litre. CASK FERMENTED CASK MATURED CASK AGED Sweet, doux, dolce etc. If its sugar content is of at least These terms may only be used in relation to a wine that bears 45 grams per litre. 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.

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

NEW ZEALAND WINEGROWERS’ LABELLING GUIDE 30TH EDITION I FEBRUARY 2020 15 Health advisory Appendix A The “e” mark The NZ standard drinks declaration should not appear on an EU The “e” mark is a symbol that may be used alongside the net wine label. It is not a legal requirement and many EU member states contents to signify that a bottle has been filled according to the calculate standard drinks of alcohol units differently. average quantity system, this must be supported by some sort CONTENT FOR PACKAGING of verification process. It is not a mandatory requirement and United Kingdom - Health Advisory theoretically an 'e' on an imported wine has no significance in the EU. In September 2017 the UK's Portman Group developed new best If you do use the mark ensure that it is near the nominal volume and practice guidance for drinks producers on communicating alcohol that you supply the importer with a copy of the records you have kept and health related information to consumers. This was developed of the hourly metrological checks you have made. Units must Or: “It is safest 1 For further health not to drink be displayed in conjunction with the UK Department of Health and is a voluntary Organic claims per container, information visit alcohol when standard. The UK Government has proactively encouraged all pregnant” as and optionally Per Wine produced in the 2012 vintage or earlier under the old organics per serve. producers to voluntarily display this labelling. You can access the an alternative 25ml to logo.equivalence arrangement may continue to bear the previous Portman Group’s guidelines on the labelling scheme here. designation of “wine made from organically grown grapes.” Wine produced from 2013 onwards will need to be labelled “organic Example label presenting theIncluded minimum at Annex elements 6 are on-pack the four with options active for signpost the new to guidance Drinkaware.co.uk. wine” and comply with the current EU regulations for such products. display panels, one of which is reproduced below. All production of wine making an organic claim must now also register as an organic exporter in the EU's TRACES electronic system. Note that the importer must also be registered. For more information see Or: “It is safest Units must The UK Chief Medical Officers mpi.govt.nz. Wines making an organic claim can only be exported 1 not to drink be displayed recommend adults do not alcoholto when the EU pursuant to the Official Organic Assurance Programme per container, regularly drink more pregnant” as and optionally than 14 units per week. operated by MPI. For further details see: foodsafety.govt.nz Per an alternative per serve. 25ml to logo. The Green Dot The Green Dot (“Grüne punkt”) signals a company’s compliance Example label featuring CMOs’Ireland Low - Health Risk Drinking Advisory Guidelines. with a German law that makes the recycling of packaging material mandatory. By paying a form of licence fee, a company is authorised In October 2018 the Public Health (Alcohol) Act 2018 was signed into to use the Green Dot on its packages, and is thus exempt from the law. This Act will require health warnings and advice on all alcoholic statutory requirement to recycle the packaging. The requirements to beverages (bottles and cans).For furtherThe Public health Health Act states that labels comply with the law are imposed on parties within Germany – in the 1 on alcohol products will haveinformation to detail: visit case of imported product this means the importer. It is therefore up • a warning to inform the public of the danger of alcohol to your importer to determine whether the Green Dot is necessary on Per consumption;25ml your labels. • a warning to inform the public of the danger of alcohol consumption when pregnant; • a warning to inform the public of the direct link between alcohol For further health and fatal1 cancers; information visit • the quantity in grams of alcohol contained in the product; • the energy value expressed in kilojoulles and kilo calories; Per • details25ml of a website (askaboutalcohol.ie) providing public health information in relation to alcohol consumption. There will be a three year transition period before manufacturers will Example labels featuring minumumhave to comply elements fully andwith otherthe labelling icons. requirements. NZW will keep members updated with any regulations or guidance issued by the Irish Government over the coming months. 7

16 © New Zealand Winegrowers I nzwine.com TRIMAN logo The French Government has recently imposed a requirement for a mandatory logo on packaging materials – ostensibly for environmental sustainability reasons. The obligation to display this logo would fall on importers, not exporters. However, due to confusion over the new law, we understand that it was not initally being enforced. We also understand it would not apply to glass. We recommend that you check with your EU agent on whether this logo is required.

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.

Recycling Statement - Italy Italian environmental law requires the inclusion of mandatory antilitter labelling on bottles for sale in Italy. This can be met by a symbol depicting a wastepaper basket or the following phrase "non disperdere il vetro nell’ambiente". The minimum type requirement is 3mm for the statement or 15mm for the pictogram. You should contact your Itallian agent for the pictogram.

Vegetarian and Vegan Claims There is no specific EU regulation that governs vegetarian and vegan claims. However the Food Standards Agency in the UK has issued guidance about making such claims on wine in the UK. As in New Zealand, the overarching requirements is the prohibition on misleading consumers, about the nature of the product. See details on Vegetarian and Vegan claims on page 8.

NEW ZEALAND WINEGROWERS’ LABELLING GUIDE 30TH EDITION I FEBRUARY 2020 17 UNITED STATES OF AMERICA

UNITED STATES LABELLING LAWS When the percentages are stated with the varieties on the brand label, they do not need to be repeated if the varieties are themselves The USA labelling regulations are contained in the Code of Federal repeated elsewhere on the label. Regulations, Title 27, Part 4. These regulations are administered by the US Alcohol and Tobacco Tax and Trade Bureau (USTTB),a division Country of origin of the Department of Treasury. All imported wine labels must bear a country of origin statement. All wines sold in the USA must first obtain a Certificate of Label This may appear on any label. TTB guidelines indicate that “Product Approval (COLA) from the USTTB. This can be applied for online at of New Zealand” is the preferred form. However, the TTB has now ttbonline.gov indicated that it will accept “New Zealand Wine” or “Wine of New

MANDATORY INFORMATION Zealand”. Presentation and placement Alcohol by volume All mandatory information must be legible and on a contrasting All wines over 14% alcohol must bear a statement of alcoholic background. In many cases, specific type size and placement will be content. Wines of between 7% and 14% alcohol must include a specified. If any of the mandatory information is contained among statement of alcoholic content unless it uses the type designation other descriptive information, then it should be of a size substantially “table wine” or “light wine” (see below). The latter option is not more conspicuous than the descriptive information. desirable in most cases, however, since it effectively precludes the use The brand name and “class and type designation” must be placed of a grape variety on the label. together. The label on which these are presented is designated the From 9 August 2013 the alcohol statement no longer needs to appear “brand label”. If these items appear on more than one label, the on the brand label. However, the following presentation requirements winery can choose which label to identify as the “brand label” when continue to apply: the statement must appear in lettering of between applying for a COLA. 1mm and 3mm in height, and may not be set off with a border or It is permitted to repeat mandatory information in other places on the emphasized in any way. The following forms of alcohol statement are label. acceptable: “Alcohol (Alc.) xx% by volume (vol.)” or “xx% alcohol From 9 August 2013 it is no longer necessary for the alcohol (alc.) by volume (vol.)” or “Alc. xx% vol. The third version can also declaration to appear on the “brand label.” A new COLA wil not be be used in the EU. Full stops must be used for the abbreviated required if this is the only change made to a label. version. Tolerance from the actual alcohol content is +/-1.5% for wines with a declared alcohol by volume content of 7-14%. There is Product Name a tax boundary at 14%, and the declared content may not be in a All wine labels must bear a “class and type designation”. This diferent tax category from the actual content. Over 14% the permitted can either be a generic description (e.g. “white wine”, “sparkling tolerance is 1% between the declared and actual alcohol. wine”3,“Port”) or a varietal statement. If you have more than one item on a label that could be a class or Net contents type designation, the USTTB will use the most specific item as the All wine must bear an indication of net contents. This may appear on class and type designation (e.g. if you have both “Chardonnay” and any label, and must be expressed in millilitres for a 750ml bottle. “white wine” on a label, “Chardonnay” becomes the class and type designation and must therefore appear on the brand label). In most Importer cases, therefore, the varietal statement will need to appear on the All imported wine labels must bear the name and address of the brand label. It must be in letters of at least 2mm in height for a 750ml importer. The form is: “Imported by [name of importer] [address of bottle. principal place of business].” This may appear on any label and must Note: you can only use a variety name as the class and type be in lettering of at least 2mm in height for a 750ml bottle. If the wine designation if your wine label also has an “appellation of origin” in is bottled or packaged in the USA, different rules apply. “Importer” accordance with the conditions below. This means that if you have a means either the holder of an importer’s basic permit making the variety on the label, you must also have a geographical indication. original Customs entry into the United States or for whom such entry The minimum content for a single grape variety is 75%. The USA is made; or the holder of an importer’s basic permit who is the agent, Overseas Market Access Requirements allow for this variation from distributor, or franchise holder for the particular brand of imported the 85% standard. Multiple varieties may be used. In that case, all alcoholic beverages and who places the order abroad. varieties must be stated, with the percentage of each variety in the The name should be that which appears on the importer’s basic blend also stated (e.g. “Cabernet Sauvignon 75%, Merlot 25%”). permit. The address should be the city and state shown on the importer’s basic permit.

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

18 © New Zealand Winegrowers I nzwine.com Brand name Geographical indication All wine labels must bear a brand name. If it does not bear one, the If you are exporting your wine to the USA, you must have a name of the bottler, packer or importer becomes the brand name. geographical indication on the label if you want to use a vintage date. The brand name must appear in “the usual distinctive design”. It Your geographical indication (called “appellation of origin”) must be must not convey an erroneous impression as to age, origin, identity a name that is listed with the USTTB as a New Zealand appellation of or other characteristics of the wine. The brand name must be at least origin. The minimum content of wine from the stated appellation of 2mm in height for a 750ml bottle. This must appear on the same label origin is 85%. as the class and type designation and the alcohol declaration. The TTB has accepted a new list of New Zealand GIs. Sulphite declaration This list is shown in Annex 1. All wines containing more than 10ppm sulphur dioxide must bear a USA rules do not permit the use of two separate geographical sulphite declaration. This may appear on any label and must be in indications on a wine label (e.g. Marlborough/Gisborne). However, lettering of at least 2mm in height for a 750ml bottle. The required if you want to use the name of a sub-region in conjunction with the form is: “Contains Sulfites” (note the US spelling) or “Contains name of a region (e.g. Awatere Valley, Marlborough) this is permitted Sulphites”. provided that both names appear on the list in Annex 1.

Health advisory If you are using a grape variety as your class & type designation All wine labels must bear a government alcohol warning. This may (which will usually be the case for a varietal wine), the appellation of appear on any label and must be at least 2 mm in height for a 750ml origin must appear on the same label and in the same field of vision, bottle, and must be in the following form: and in lettering substantially as conspicuous, as the class and type designation. GOVERNMENT WARNING: (1) According to the Surgeon General, women should not drink alcoholic beverages during pregnancy Note that NZ rules represent a baseline that must be met in addition because of the risk of birth defects. (2) Consumption of alcoholic to the US rules. beverages impairs your ability to drive a car or operate machinery, and may cause health problems. NZW has sought legal advice from US attorneys which confirms that it is not permitted in the USA to include wine of non-New Zealand origin The first two words must be in bold and in capitals. The remainder of into a wine labelled as originating solely in New Zealand. In addition, the statement must appear as a continuous paragraph and may not TTB has confirmed that if the wine bears a New Zealand registered appear in bold. The number of type characters may not exceed 25 GI the wine must be 100% New Zealand wine. Under mandatory per inch for 2mm minimum type size. labelling regulations in the United States, if a country of origin other The NZ standard drinks declaration should not appear on a US wine than the United States is shown for a wine, the exact percentages of label. It is not a legal requirement and the US calculates differently wine from each country must be disclosed. Therefore, a wine blended from NZ. Similarly, health advisory information other than the Surgeon in the United States from bulk wines from New Zealand and the United general’s Warning should not appear on a US label. States, whatever the proportions, would have to be labeled with an indication such as one of the following: OPTIONAL INFORMATION Vintage - “Wine of New Zealand __% and the United States __%” ; or A vintage date can only be used if the wine also has a geographical - “__% New Zealand Wine and __% American Wine”. indication (called “appellation of origin” including a country name e.g. A copy of the legal opinion can be found under the Compliance tab in “New Zealand”) . the SELL section of the members website at nzwine.com. The wine must contain at least 85% content from the labelled vintage. 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…”).

NEW ZEALAND WINEGROWERS’ LABELLING GUIDE 30TH EDITION I FEBRUARY 2020 19 Estate bottled Prohibited information The term “estate bottled” can only be used if 100% of the wine came There is a fairly lengthy list of things that are prohibited on a US from grapes grown on land owned or controlled by the winery, which wine label, although most of them would not be relevant to the must be located in the viticultural area that appears on the label. The average New Zealand wine producer. Additional information must not producer must crush and ferment the grapes, finish, age and bottle be obscene or indecent; give the impression that a wine contains the wine at the same winery in the stated viticultural area. distilled spirits or has intoxicating qualities (!); give the impression it belongs to a different class and type (e.g. words such as “lively”); Allergen declaration simulate any sort of Government stamp; make claims about curative Allergen declarations are currently not mandatory on the labels of or therapeutic effects etc. In addition, still wines are prohibited from wine sold in the USA. However, where an allergen declaration is used, using terms which allude to any sparkling characteristics (such as all allergens used in the production of the wine must be declared in frizzante, crackling, tingly, bubbly or cremant. 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.” Vegetarian and Vegan Claims Vegetarian and Vegan claims are not regulated specifically under US Serving Facts law. However TTB has advised that: On 28 May 2013 the TTB issued a ruling that permits the voluntary • you may not make a claim like "vegetarian wine" or "vegan wine", use of serving facts statements on labels. The ruling allows “Serving Facts” statements that include the serving size, the number of • but you may claim "vegetarian friendly wine" and "vegan servings per container, the number of calories, and the number of friendly wine"; or grams of carbohydrates, protein, and fat per serving. Additionally, • you may simply use the words "vegerarian" or "vegan" by itself. Serving Facts statements may include information about the alcohol content of the product as a percentage of alcohol by volume and Overstickering may also include a statement of the fluid ounces of pure ethyl alcohol The TTB will usually not permit over stickers to cover any part of per serving. It will not be necessary to apply for a new COLA to add an existing label. In some circumstances the TTB will approve over a Serving Facts statement, provided the statement conforms to the labelling but only as a "use up" for a certain time frame. examples contained in the ruling: www.ttb.gov/rulings OTHER INFORMATION Organic claims Labels may contain additional information provided that it does The Department of Agriculture has stringent guidelines for organic not conflict with or contradict mandatory information. Additional labelling. The USDA accepts the MPI’s programme for recognition information must be truthful, accurate, specific and not disparaging of of organic certifying bodies. As such, organic products certified by competitors’ products, false or misleading. 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. The TTB has also prepared some guidance on labelling organic wine available here.

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”. If the Trans- Pacific Partnership comes into force you will not be able to use the term "Ice Wine" except on wine from grapes naturally frozen on the vine.

20 © New Zealand Winegrowers I nzwine.com CANADA

CANADIAN LABELLING LAWS There is nothing specific in Canadian Federal law about tolerances for Canadian labelling requirements are found in the Consumer Packaging the alcohol declaration, although this may be covered by the general and Labelling Act and Regulations and the Canadian Food and provisions in Canadian food labelling laws related to misleading Drugs Act and Regulations. A useful guide to their labelling regime labelling. We understand that, in practice, the provincial liquor boards can be found on the Canadian Food Inspection Agency alcoholic in Ontario and Quebec currently operate a tolerance of +/- 1%. beverage site. Net contents

MANDATORY INFORMATION All wine labels must bear a declaration of net contents. For quantities Presentation and placement of less than 1 litre, this should be expressed in millilitres (e.g.750 ml). Canadian law requires that all mandatory information (except net The acceptable symbols are ml and mL. contents and alcohol content which are bilingual) be presented in both French and English. Both language versions must be on the The product name, country of origin, alcohol and net contents must same label in the same type. Canada has now amended its laws to appear in a single field of vision. This can be on either the front or comply with the World Wine Trade Group Labelling Protocol. This back label. For a 750 ml wine bottle, no taller than 360 mm, the means that mandatory information can be presented on either the declaration of net quantity may be shown in letters of not less than front or the back label, allowing exporters to use the “clean” multi- 3.3 mm in height. market front label option for Canada. The net contents declaration should technically be in English and A minimum type size of 1.6mm in height based on the lowercase French, although “750 ml” would be considered to be bilingual and letter “o” is specified for most mandatory information. Other therefore does not have to be repeated. mandatory information must be easily read and clearly and Note: wine can only be sold in Canada in standardized container prominently displayed, and the 1.6mm standard is recommended. sizes – i.e. 50, 100, 200, 250, 375, 500, 750 millilitres and 1, 1.5, 2, 3 or 4 litres.

Product name Producer / Importer All wine labels must bear the common name of the product in both All wine labels must bear the name and principal place of business French and English, e.g. “wine / vin”. This must be in letters of at of the person by whom or for whom the wine was produced. The least 1.6mm in height based on the size of the lowercase “o” (even business identity is the registered name of the company. The principal though there is no “o” in wine). It is also permissible to use an place of business should include the city or town and the country. adjective (e.g. red wine/vin rouge) The product name, country of This may appear anywhere on the label. The minimum type size is origin, alcohol and net contents must appear in a single field of vision. 1.6mm based on the lowercase “o”. This must be shown in English This can be on either the front or back label. and French.

Country of origin If you are using the name of a Canadian agent to meet the producer name requirements, then you must say “Imported by/Importé par All wine labels must indicate the country of origin. This must be in ” or “Imported for/Importé pour ” or else use a geographical indication immediately Zealand – Produit de Nouvelle-Zélande” or “New Zealand Wine - Vin adjacent to the Canadian agent’s details in type of the same size or de Nouvelle-Zélande”. There is no minimum type size requirement, larger. The preferred wording for wine to be sold in Quebec (via the but the 1.6mm standard is recommended. The product name, country SAQ) is “represented by / représenté par”. of origin, alcohol and net contents must appear in a single field of vision. This can be on either the front or back label. Allergen declaration

Alcohol by volume Canada’s allergen labelling regulations came into force on 4 August 2012. All non-vintage wines and wines with a vintage date All wine labels must bear a declaration of alcoholic content. This can of 2012 and later must meet the new allergen labelling requirements appear as either “x% alcohol by volume” or “x% alc./vol.” (full stops and no vintage date. must be used in the abbreviated version). The abbreviated version is considered to be bilingual and therefore does not need to be Lot number repeated. The minimum type size is 1.6mm based on the lowercase A lot identification code should be placed on a wine container. The code “o”. The product name, country of origin, alcohol and net contents should be clear, specific, truthful, accurate and not misleading, and as long must appear in a single field of vision. This can be on either the front as the identification code is legible by physical or electronic means – there or back label. is no specific font size, or phrasing of formatting for the code. Provincial Liquor Control Boards may have additional requirements, please discuss these with your Canadian distributor.

NEW ZEALAND WINEGROWERS’ LABELLING GUIDE 30TH EDITION I FEBRUARY 2020 21 Sulphites Geographical indications Where a wine contains sulphite levels of 10mg/L or more the While Canada does not have any specific minimum content declaration will be required in English and French, and the specified requirements for variety, vintage or geographical origin (other form will be: “Contains sulphites / Contient des sulfites”. Any of than country of origin) in its national legislation, the guidelines for the following common names will be accepted: “sulfites”, “sulfiting Canadian Vintner’s Quality Alliance (VQA) wines are instructive: agents”, “sulphites” and “sulphiting agents.” • single-varietal VQA wines, where the variety is indicated on the front label, not less than 85% of the wine shall be made Eggs, Fish or Milk Products from the named individual grape variety If an allergen is present due to the use of fining agents from eggs, • dual-varietal VQA wines, where the varieties are indicated on the front label, not less than 95% of the wine shall be made fish, or milk, the allergen must be declared on the label (also in the from the two varieties named, with the second being not less “contains [allergen]” form) in both English and French. Because than 15% of the total the Canadian legislation requires allergens to be declared only when In every case, the declared varieties shall be listed on the principal present in the final product, allergen labelling will be required only if display panel in descending order of quantity, in identical type and the fining process leaves behind some protein from the food allergen identically displayed. in the wine. While the regulations do not provide a specific threshold level, typical test methods for food allergens can detect in the low Standard drinks parts per million (ppm) range and if these methods did not detect any The NZ standard drinks declaration should not appear on a Canadian protein from the food allergen in the wine, then it could be considered wine label. It is not a legal requirement and Canada calculates that no protein was present and no label statement is required. differently from NZ. Canadian industry has produced a guidance document on the labelling of fined wines which provides an example of the process which may Environmental, sustainability and organic claims be required to support a decision not to label, Canadian Industry Canada introduced new organic regulations in June 2009. Products Fining Guidelines cannot use the term ‘organic’ or another term which infers the The Winemaker should determine, on a case-by-case basis, whether product is organically grown unless it has been certified under residues are, or are likely to be, negligible in quantity (and thus in the Canadian Organic Standard (COS). It is possible to obtain an public health significance) and in technical effect in the wine that equivalency agreement with Canada, however, MPI’s official assurance will be offered for sale. Supporting evidence to assist in making this system is not currently recognised. evaluation might include: We do understand that Assure Quality and BioGro have a recognised 1. The unit processes to which the product will be exposed after relationship with the Canadian Organic Standard. For more fining that will serve to reduce or eliminate residues of fining information about Organic requirements in Canada you should get in agents or their by-products from the wine (i.e., the filtration touch with either Assure Quality or BioGro. processes, blending steps, etc.); and/or Please note that organic statements are required to appear in both 2. Data from analytical tests showing that the residue levels are at French and English. or below a level of 1 mg/L” In summary, the Regulations provide that only wine certified to either the Canadian or USDA NOP standard can be sold or marketed as an RECYCLING STATEMENT organic product. Certificates or letters from the certifying agency must Many provincial Liquor Control Boards require a recycling statement be submitted to the LCBO to support all organic or biodynamic claims. to appear on the label. The statement can appear on any part of the Suppliers must be prepared to provide proof (preferably third party bottle, execpt for the bottom, the type size in 1.6mm. The wording of certification) of any claim involving sustainable agriculture, “green” the statement is as follows: practices, etc. Return for refund where applicable/Bouteille consignée selon la loi

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.

22 © New Zealand Winegrowers I nzwine.com 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 applies 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. 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

NEW ZEALAND WINEGROWERS’ LABELLING GUIDE 30TH EDITION I FEBRUARY 2020 23 CHINA

CHINESE LABELLING LAWS Net contents The net contents must be on the same display panel as the word The key items of labelling legislation are the wine standard (GB ‘wine’. This should be marked as ‘net content xxx Ml (ml)’ for bottle 15037) and the wine labelling law (GB 10344) both of which are sizes under a litre, or ‘net content x Litres (l)’ for bottle sizes over administered by the General Administration of Quality Supervision, a litre. For packages up to and including 200ml the minimum print Inspection and Quarantine of the People’s Republic of China. As height is 3mm. From 200ml up to and including 1 litre the minimum there are significant difficulties involved in interpreting and translating print height is 4mm. For packages greater than 1 litre the minimum these standards, we strongly advise that you consult your agent in print height is 6mm. the relevant market to confirm the requirements before labelling your wine. Importer

MANDATORY INFORMATION The name and address of the Chinese agent, importer or distributor must be shown on the label. The name and address of the producer Presentation and placement is not mandatory, however if included it does not need to be Wines sold in the Chinese market must bear mandatory information translated into Chinese characters. The minimum type size is 1.8mm. in Chinese characters. This means that a special label needs to be This may appear on any label. produced for the Chinese market. The minimum type size for most mandatory label information is 1.8mm. Lot identification Chinese law bans the use of temporary adhesive labels, although The date of bottling is required on Chinese labels. The minimum type some foreign wineries continue to attach small and simple labels size is 1.8mm. This may appear on any label. (translated into Chinese) on the outside of the bottle. This is done Compliance with this requirement could be extremely difficult as the either prior to delivery to China or by the Chinese importer under the standard batch or lot labelling using the Julian date code does not supervision of a Chinese inspection and quarantine organisation. appear to be acceptable to the Chinese. Neither can the bottling This is a risky option to take and, as such, New Zealand Trade and date be applied in the form of a sticker, reprint or tampering which Enterprise recommends that exporters strictly abide by the formal suggests that the label itself must contain the required information. labelling regulations when developing business in China. We suggest that negotiation with your bottler is required in order to satisfy this traceability requirement. Product name The name of the product is mandatory in China. The words ‘grape Best before date wine’ should be sufficient, however it is advisable to qualify this with Wines with an alcohol content of 10% or less are required to include ‘red’, ‘white’, ‘sparkling’, ‘semi-sparkling, ‘fortified’, ‘sweetened a minimum durability date. The minimum type size is 1.8mm. This fortified’ etc. The minimum type size is 1.8mm. This may appear on may appear on any label. Wines over 10% alcohol are exempt from any label. this requirement (GB7718-5.2.1 and GB10344-5.2). Nevertheless many importers and/or regulatory authorities seem unaware of Country of Origin this exemption and it is advisable to include a statement such as A country of origin statement is mandatory. Importers will usually ‘recommended to drink before (year)’. request a Certificate of Origin to confirm this claim. Certificates of Origin can be obtained from your local Chamber of Commerce. Be Health advisory sure to ask for the NZ-China FTA certificate of origin, not the generic A recent amendment to the Chinese wine standard requires all labels one. The minimum type size is 1.8mm. This may appear on any label. to include a health warning from 1 August 2013. The recommended text is: “excessive drinking is harmful to health.” Alcohol by volume

The alcohol declaration should be in the form ‘Alcoholic strength Note: All Mandatory Information must be in Chinese characters, xx.x% vol’. (Apparently % Mass is also acceptable and this may this includes: account for some of the reported disparity between results obtained Product Name, Lot ID, Alc. by volume, best before date, Net contents, from testing authorities within China). The tolerance between the Health Advisory, Importer. actual and the stated alcohol is +/- 1.0% in China. The minimum type size is 1.8mm.

24 © New Zealand Winegrowers I nzwine.com 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 or equal to 0.35 MPa at 20oC (for bottles with a capacity of less than 250 ml, 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 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 15.0-22.0% (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

Ingredients Only products made from a single raw material are exempt from should also be declared. It is not necessary to list processing aids the requirement for ingredient listing. This means that sweeteners, (although it is worth noting that there is a proposal in draft form for preservatives and added colour (legal in the case of fortified wine allergenic processing aids to be labelled). The minimum type size is only) need to be declared in descending order of their weight. 1.8mm. This may appear on any label. Ingredients constituting less than 2% of the food are not required to be listed in descending order. Optional information The list of ingredients for wine should have the title of “raw material” Vintage, variety, and geographic indications can be used. Though or “raw material and auxiliary material”. The name of the substance the composition requirements differ in China (75% minimum content (sulphur dioxide, sorbic acid etc) should be declared rather than the requirement) you must comply with the New Zealand thresholds if you generic category, for example, ‘preservative’ or ‘colour’. Added acids wish to include these.

NEW ZEALAND WINEGROWERS’ LABELLING GUIDE 30TH EDITION I FEBRUARY 2020 25 JAPAN

JAPANESE LABELLING LAWS Ingredient listing

Wine for sale must comply with the labelling standard regulations The names of any food additives should be shown in descending based on the Law Concerning Liquor Business Association and order of proportion by weight. Relevant additives are preservatives Measures for Securing from Liquor Tax, the Food Sanitation Law, or antioxidants, which should be listed preceded by the word and the Measurement Law. For imported wines, both importing and “preservative” or “antioxidant” (examples provided by the Japanese wholesaling companies are responsible for indicating the following on Government are SO2, sorbate and ascorbate). The minimum type size product labels. is 2.8 mm. This must appear collectively with product names, alcohol content, country of origin, and carbonation statement. MANDATORY INFORMATION Carbonation statement Mandatory information on the label must be in Japanese. This means A statement is required as to whether or not a wine is carbonated. that a special label needs to be produced for the Japanese market. The minimum type size is 2.8 mm. This must appear collectively with The minimum type size for most mandatory information is 2.8mm. product name, alcohol content, country of origin, and food additives.

Product name Health advisory – Consumption by minors This should be a common name, such as “wine”. The minimum type All wine labels should bear one of the following statements: size is 2.8mm. This must appear in conjunction with alcohol content, “Consumption of alcohol by minors is prohibited” or “Alcohol may only country of origin, food additives, and carbonation statement. be consumed by those 20 or over”. The minimum type size is 2.8mm.

Country of Origin OPTIONAL INFORMATION 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 Vintage, variety and geographical indication claims are optional. You product name, alcohol content, food additives, and carbonation should comply with the New Zealand thresholds if you wish to include statement. these.

Health advisory – Pregnancy labelling Alcohol by volume This should be rounded to the nearest percentage point and be A health warning on the label is a voluntary industry standard and expressed as follows: “x degrees or more to less than y degrees relates to the risks of alcohol to pregnant and breast-feeding women. alcoholic content”. The difference between x and y must be no more The advisory statement should warn pregnant and nursing women than 1 degree of alcoholic content. So, for example, a wine with that the consumption of alcohol may adversely affect their infant’s 12.6% alcohol should be labelled: “12 degrees or more to less health. For example, “Drinking alcohol while pregnant or breast- than 13 degrees alcohol.” The minimum type size is 2.8 mm. This feeding may harm the foetus or infant.” must appear collectively with product name, country of origin, food Environmental, sustainability and organic claims additives, and carbonation statement. In order to be able to use organic labelling in Japan, your product Net Contents must meet the requirements of the Japan Agricultural Standards This can be expressed in either millilitres or litres. The minimum type (JAS) law. New Zealand producers can arrange to be certified in New size is 2.8 mm. Zealand under MPI’s organic programme, which is recognized by JAS. Use of the term “Organic” must comply with a Codex Alimentarius- Importer based labelling standard. The name and address of the importer must appear on the label. A voluntary carbon footprint (CF) labelling pilot was launched by the Details must be sufficient to allow a consumer to contact the importer. Japanese Government in 2009. Participating products must indicate

If the distributor is different from the importer, the distributor’s details in numerical form the estimated CO2 emissions created during the should also appear. The minimum type size is 2.8mm. product’s life cycle. If you are interested in participating, contact New Zealand Winegrowers for more information on the scheme.

26 © New Zealand Winegrowers I nzwine.com SOUTH KOREA

SOUTH KOREA’S LABELLING LAWS Net contents

Importers must obtain a license from the regional tax office to Net contents must appear on the front label. No format is specified. import alcoholic beverages including wine. The import of wine is not Producer restricted in Korea, but is subject to inspection by the Korea Food & Drug Administration (KFDA). Producers exporting to Korea are The name of the producer must appear on the label and can be stated in English. (“Made by company name, address and country now required to register online through the Korea Food and Drug name”). Administration. Please check registration requirements with your agent. For any initial shipment into the market, a close inspection Importer usually takes 18 days. Inspections of subsequent shipments usually The importer name, address and phone number must appear on the take three to four days if the product is identical in label, product label and must be sufficient to enable the consumer to identify and name, alcoholic content, vintage and bottle size. For more information contact the importer so that returned products can be exchanged if see nzte. defective. You should also include the importer’s Business License MANDATORY INFORMATION Number (which can be obtained from your importer).

Presentation and placement Brand name Mandatory information must be written in Korean. English can appear The label must bear a brand name. This must be at least 2.1mm in on the label with Korean, but these words should be equal to or less height and must appear on front label. than the size of the Korean letters. Country of origin, product/brand name, and the name and address of the overseas manufacturing Lot identification company do not have to be translated into Korean. Stickers may Alcoholic beverages must have one of the following labelled on be used but should not be easily removable, or cover the original the product: (1) Date of manufacture; (2) Bottling Date; or (3) labelling. Korean food importers can prepare labels in Korean and Manufacturing Serial Number (i.e. Lot Number or Code). This stick to bottles in a bonded warehouse in Korea prior to customs information must appear on the Collective Display Panel. clearance. Date of Manufacture should be written: “yy.mm.dd”, or “yyyy.mm.dd” or “yyyy/mm/dd”. Product name Bottling Date should be written: The product type ‘grape wine’ may be further classified by colour as “yy.mm.dd”, or “yyyy.mm.dd” or “yyyy/mm/dd”. 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 This must appear on the same label as the ingredient and additives is less than 7.76mm, the product type must be at least 2.47mm. If the list. product name is greater than 7.76mm, the product type must be at Storage instructions least 4.23mm. The product type must also appear on the front label. Storage instructions must appear on the label. The format is not Country of Origin specified. The country of origin must be labelled in a conspicuous place and be Carbonation statement legible, indelible, and permanently marked. Carbonated products must indicate on the label that they Alcohol content are carbonated. An alcohol declaration is mandatory in Korea. The format is not Ingredient list prescribed by the regulations. The KFDA test whether the alcohol content maintains a 0.5% tolerance level between the labelled and The ingredient(s) used must be listed in descending order of weight actual alcoholic content. 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. The addition of sorbic acid should also be declared. These must appear on the same label as the date of bottling.

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

NEW ZEALAND WINEGROWERS’ LABELLING GUIDE 30TH EDITION I FEBRUARY 2020 27 Health advisory The following two statements are mandatory: “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”. Note that South Korea has notified a proposed significant new health warning label. We recommend that you check with your importer for further information.

Mode of Distribution

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

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.

28 © New Zealand Winegrowers I nzwine.com RUSSIA

RUSSIAN LABELLING LAWS Health advisory

The following summary of the Russian labelling regulations is drawn Two health warnings must appear on the label or container. The first from information provided by Market New Zealand and the Australian warning must state “Excessive alcohol consumption is dangerous to Grape and Wine Authority. However, there are significant difficulties your health”. It must appear in bold, clear, capital letters of the largest involved in interpreting and translating these standards and we possible font occupying at least 20% of the front or back label or strongly advise caution in applying the following information. Note that consumer container. Russia has proposed new labelling laws. It is not clear when these will All wine labels must also include the following health warning: come into force. You should consult your agent in the relevant market “Not recommended for use by individuals under the age of 21 to confirm the requirements before labelling your wine. years, women who are pregnant or breastfeeding, or individuals with diseases of the nervous system or internal organs”.

MANDATORY INFORMATION Sugar content Product name An indication of the sugar content of the wine must appear on the All wine labels must bear the name of the product. For a typical label as follows (for standard wine): New Zealand wine, this will usually be the term “wine” which can be - dry <4g/L or <9g/L provided the total acidity of titrated acids is supplemented with the colour of the grape variety. However, it should <2g/L below the residual sugar content be noted that the Russian regulations have a long and complex list - semi-dry 4-18g/L of definitions for different permutations of the product. We strongly - semi-sweet 18-45g/L advise that you seek advise from your importer as to the appropriate - sweet >45 g/L product name to apply to your labels. Ingredient list

Country of origin In addition to a list of the ingredients contained in the alcohol, it is A country of origin statement is mandatory on all imported products. also mandatory to include names of food supplements, biologically active supplements and any genetically modified organisms used in Alcohol content the wine’s production. The alcohol content is mandatory on all labels. The preferred form is Russian law also requires a list of components listed in descending % of total volume. For standard wine, a tolerance of +/-1% will apply. order of their mass fraction. Presumably this refers to the ingredients, however we advise that you seek clarification from your importer Net contents regarding the presentation of this requirement. The volume statement must appear on the label in either L, or mL. Allergens Importer / producer The label must contain an indication of the presence of sulphites over The name and address of both the importer and the exporter must 10mg/L as well as milk, eggs, fish and their derivatives. be shown on the label. The address must be sufficient to enable the consumer to identify and contact the importer. Nutritional information We have previously been advised that a statement of nutritional Bottling & expiry date content is mandatory. However, the current status of this requirement The date of bottling (which may be the production date) and expiry is now uncertain. We recommend that you seek clarification from your date must appear on the label. For typical wine, the expiry date will importer. be unlimited and the label will therefore need to bear the following statement: “The expiry date is unlimited if the storage conditions are Mark of Conformity and technical reference observed.” The storage conditions for wine should also be included A mark of conformity (the GOST-R symbol together with the on the label. certification body registration number) is mandatory. Certified products should be marked by the Registered Eurasian Conformity mark. A reference to the technical document under which the product was made is also mandatory.

NEW ZEALAND WINEGROWERS’ LABELLING GUIDE 30TH EDITION I FEBRUARY 2020 29 Barcode A UNISCAN barcode must appear on the packaging.

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.

OPTIONAL INFORMATION

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

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.”

30 © New Zealand Winegrowers I nzwine.com BRAZIL

BRAZILIAN LABELLING LAWS MANDATORY INFORMATION

Brazilian labelling requirements are found in the Brazilian Consumer United States Department of Agriculture reports state that it is Protection Law number 8,198. As there are significant difficulties common practice in Brazil for importers, agents, or distributors to affix involved in interpreting and translating these requirements we to the wine bottle an additional small adhesive label in Portuguese, strongly advise caution in applying the following information. You with the name and address of the importer and the company’s tax should consult your agent in the relevant market to confirm the registration number. requirements before labelling your wine. The following information must also appear on the label: Once the product reaches Brazil, in order to clear customs, imported • Product name wines are subject to chemical analysis to verify that they meet • Country of origin international requirements. Port authorities working for the Ministry • Alcohol declaration of Agriculture will take one sample for analysis. The Brazilian importer will deposit the imported merchandise in storage until the laboratory • Net contents (in metric units) test results are confirmed. • Validity date (shelf life) • Date of production Product name • Food Additives (if any) The following categories of wine are recognised by Brazilian authorities: a. Table wine (including effervescent table wine) Geographical Indications b. Natural sparkling wine Geographical indications must not be used to describe wines exported c. Carbonated sparkling wine to Brazil unless the geographical indications are included in Annex 2 d. Liqueur wine of this Guide. e. Fortified wine A warning statement in Thai must be included in a conspicuous place

Wine is further categorised based on total sugar content:

a. Table wine i.i. DryDry –– maximummaximum ofof 4.04.0 g/Lg/L glucoseglucose ii.ii. MediumMedium drydry –– betweenbetween 4.04.0 andand 25.025.0 g/Lg/L glucoseglucose iii.iii. Sweet/MildSweet/Mild –– minimumminimum ofof 25.025.0 g/Lg/L glucoseglucose

b. Sparkling wine (Champagne) i. Gross (Brut) – maximum of 8 - 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.

NEW ZEALAND WINEGROWERS’ LABELLING GUIDE 30TH EDITION I FEBRUARY 2020 31 OTHER ASIAN ECONOMIES

We have included below information on the labelling requirements • Warning: Sale of liquor to person under 20 years old is prohibited. of several key Asian markets. This information is not as detailed as • Drinking alcohol reduces driving ability that provided for other markets, due to the difficulty of obtaining up • Not suitable for person under 20 years old. 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 In October 2015 additional requirements on alcoholic beverages consider when exporting to those markets. You should consult your came into force, which specifies that labels of alcoholic beverages agent in the relevant market to confirm the requirements before must not use any of the following messages: labelling your wine. 1. Messages which are unfair to consumers or which leads to social This information is taken directly from the acknowledged sources, consequences including: largely without commentary from us. Our key source is the excellent • Messages which are false or misleading; set of market reports provided courtesy of New Zealand Trade and • Messages which mislead as to the content of the product Enterprise. We highly recommend that you explore this free resource including unrealistic or exaggerated information; for yourself at nzte. • Messages that directly or indirectly support an illegal or immoral activity or which discredits the national culture; HONG KONG • Messages that lead to disharmony or prejudice to society or its Wine or alcoholic drinks with an alcoholic strength by volume of 10% people. or more as determined under section 53 of the Dutiable Commodities 2. Messages which directly or indirectly persuade consumption or Ordinance (Cap 109) (L.N. 85 of 2004; L.N. 139 of 2004) are which exaggerates the benefits or quality of alcoholic beverages. exempted from Schedules 3 of the Food and Drugs (Composition and Labelling) Regulations except paragraph 3 (see details on the website 3. The messages described in 2 above to include the following: www.fehd.gov.hk). • Messages that introduces an attitude that drinking alcohol can In effect, this appears to mean that the general food labelling lead to social and sexual success including health; standards do not apply to wine, although there is a requirement for an • Reference to or pictorial of an athlete; alcohol declaration in other legislation. Nevertheless, it is very likely • Reference to or pictorial of an artist or singer; that importers/distributors will have their own additional requirements for wine labels. • Pictorial of a cartoon; • Messages that persuade or convince purchase or consumption THAILAND in order to donate money to charity; • Messages that persuade or convince participation in activities Imports of alcoholic beverages including wine are under the such as music, sports, contests or recreation. responsibilities of The Excise Department (EXD) and The Customs Department. The specific pieces of regulation which apply are the Labels should not use 'cartoon images', except where these are Ministry of Public Health Notification No. 367 B.E. 2557 (2014) Re: existing trademarks. Labels should not overstate the properties, Labelling of Pre-Packaged Foods as well as Notification No. 275 B.E. benefits or quality of the product including the use of 'finest', 2540 (1997) Re: Labelling Requirements for Alcoholic Beverages. 'premium', 'light', 'low calories'. The EXD’s responsibilities include labelling, licensing, and product We understand that the Thai government intends to amend to clarify quality control. The following nine items must appear on the same these rules or issue guidance to clarify their intent. Please check with label in either English or Thai (except for the health warning, which your agent for any update. must appear in Thai):

• brand name MALAYSIA • product name • alcohol content The Malaysian Food Regulations 1985 prescribe that the following • country of origin seven items must appear “conspicuously” and “prominently” on the • importer or producer’s name and address (not postal) same label in either English or Bahasa Malaysia: • health warning (see below) • product name (ie “wine”) – 3.5mm • volume statement • alcohol statement (must state, in capital, bold lettering: • food additives (must state “preservatives used”) “ARAK MENGANDUNGI - %ALKOHOL MEMINUM ARAK BOLEH • lot number MEMBAHAYAKAN KESIHATAN”) – 4.2mm A warning statement in Thai must be included in a conspicuous place • country of origin – 1.5mm on the container. It must be easily visible and in bold characters of not less than 5mm in height and should be presented in a rectangular • importer’s name and address (not postal) – 1.5mm frame. The colours of the frame and the statements must be in • volume statement – 3.5mm contrast to the colour of the background. The wording was amended • food additives (must state “contains permitted [additive]”) by the Alcohol Consumption Control Act in February 2008. The – 1.5mm warning statements are as follows: • lot number

32 © New Zealand Winegrowers I nzwine.com SINGAPORE TAIWAN There are no specific wine standards or labelling requirements It is compulsory for imported wine to carry a Chinese language label. in Singapore, but wine products are subject to the general food Stickers may be used but should not be easily destroyed or damaged. standards and labelling requirements. Labels should include the following mandatory information printed The following basic items are required to be declared on labels in clearly and legibly: English: • brand name (may be in English)

Product name • product type A common name or a description which is sufficient to indicate the • country of origin true nature of the food product should be included. The common • alcohol statement (must be labeled by degrees eg XX% vol) name for wine shall also mean any words indicating the specific type • health warning of grapes from which the wine is made or the locality from which the • producer’s name and address grapes used originated or the locality in which the wine was made. • importer’s name and address Country of origin • lot number (imported wine harvested and produced only once a The name of the country of origin of the food should be indicated on year should adopt its date of manufacture as its lot number) the label for imported food. • sulphur dioxide statement (wine containing more than 250mg/L but less than 400 mg/L of sulphur dioxide must be labeled: ‘this Alcohol content product contains less than 400 ppm of sulphur dioxide’) The format for this is not prescribed. Vintage, variety and geographical indication claims are optional. If wines of different ages are blended, the label can only refer to the Net contents youngest one. 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 PHILIPPINES other measure should be printed on the label to indicate the quantity The importation of wine into the Philippines is regulated by its Food of the contents. In the case of weight measure, suitable words like and Drug Administration (FDA). Labels should include: “Net” shall be used to describe the manner of measure. • the name of the product

Importer • country of origin • ethyl alcohol content (% alcohol by volume or proof) In the case of an imported food, the label should indicate the name • name and address of the manufacturer and address of the local importer, distributor or agent. Telegraphic, • contents in millilitres 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.

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

NEW ZEALAND WINEGROWERS’ LABELLING GUIDE 30TH EDITION I FEBRUARY 2020 33 INDIA INDONESIA Labelling regulations in India are governed by the Food Safety and The National Agency of Drug and Food Control (NADFC) is responsible Standards (Packaging and Labelling) Regulations 2011, and the for issuing permits for wine imported into Indonesia, and for its Standards of Weights and Measures (Packaged Commodities) Rules inspection, any laboratory testing, and the exercise of related 1977. This update incorporates the Food Safety and Standards investigation and enforcement powers. Imported wine must be (Alcoholic Beverages Standards) Regulation 2018 which took effect manually registered with the NADFC before being distributed for sale. on 1 April 2019. The importation of alcoholic beverages into Indonesia is quota-based The following six items must appear on the Principal Display Panel and importers must be appropriately registered. Product packaging (PDP)4 in either English or Hindi in Devnagri script: requirements are governed by the Standar Nasional Indonesia, or • name of product “SNI”. The SNI apparently references the Codex Alimentarius. For • ingredient list alcoholic beverages, compliance with the SNI product packaging • name and address of manufacturer and importer requirements is voluntary. • volume statement The following information must appear on the label: • lot number • the product name • standard drinks statement • net contents • sugar content • name and address • allergens statement of the manufacturer • health warning • ingredients list • packaging date • food registration number The following two items of information may appear anywhere on the • expiry date; label • production code • alcohol statement (no prescribed format – you may use the New • health warning Zealand calculation method) • alcohol content The NADFC requires that labels: are not easily • country of origin separated from the product; are not easily worn or damaged; The minimum print height is 1mm or 2mm when blown, formed, and are located on the product in a way that is easy to see and moulded or perforated on the container, however the volume read. statement, lot number and packaging date must be at least 4mm. By October 2019, wine will need to be clearly labelled as “nonhalal”. Ingredients must be listed in descending order of their composition Halal certification will be mandatory for all food, products by that date, by weight or volume. If gelatine is used as an ingredient, the following but wine is not permitted to include halal certification. declaration must be included: “Gelatine – Animal Origin”. Antioxidants and preservatives must be declared and prefaced with the word “Antioxidant” or “Preservative”. Wine is exempt from the requirement for food products to bear either the brown dot or green dot symbols for vegetarian or non-vegetarian products.

34 © New Zealand Winegrowers I nzwine.com

ANNEXANNEX 1 1– – Appellations Appellations of of origin origin forfor useuse inin thethe USAUSA

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

List of Wine Regions: New Zealand Designated as belonging to one of the Three Categories of Wine Region As set out in the WWTG Labelling Protocol1

This notification is submitted in accordance with the WWTG Labelling Protocol Article 4.3(e):

“Each Party may provide the names of its wine regions categorised as belonging to one or more of the categories set out in the definition of “wine region”, to the electronic depositary, which maintains and publishes such information on the WWTG website”

Definition of “wine region” in Article 1(g) of the WWTG Labelling Protocol:

“Wine region” means, within a single country: a state, province, territory or similar administrative or political subdivision; or a single delimited grape growing area; or a grape growing region or locality as defined in the exporting Party’s laws, regulations, or requirements.

Explanatory Note: The following regions and geographical sub-units are used to label wine produced in New Zealand in accordance with the New Zealand Wine Act 2003 and the Wine Specifications Notice 2006.

Name of Wine Category of Wine Region Further Region information state, single grape growing province, delimited region or territory or grape growing locality similar area administrative or political subdivision

East Coast 

North Island May be accompanied by the name of a  geographical sub- unit, e.g.: Ohau, Pohangina Valley,

1 PROTOCOL TO THE 2007 WORLD WINE TRADE GROUP AGREEMENT ON REQUIREMENTS FOR WINE LABELLING CONCERNING ALCOHOL TOLERANCE, VINTAGE, VARIETY, AND WINE REGIONS

NEW ZEALAND: WINE REGIONS NOTIFICATION TO THE WORLD WINE TRADE GROUP ELECTRONIC DEPOSITARY 1 NOVEMBER 2013

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Taranaki, Manawatu, Horowhenua.

South Island 

Northland May be accompanied by the name of a geographical sub- unit e.g.: Karikari  Peninsula, Paewhenua island, Bay of Islands, Tutukaka Coast, Mangawhai, Whangarei.

Auckland May be accompanied by the name of a geographical sub-  unit e.g.: Ihumatao, Awhitu, Brookby, Great Barrier Island, Karaka, Ihumatao

Clevedon 

Western Auckland i Each of these (comprising names Henderson, Henderson, Huapai, Huapai, Kumeu, Waimauku)i Kumeu, or  Waimauku may be used individually instead of “Western Auckland” where appropriate.

Matakana 

Waiheke Island May be accompanied by the  name of a geographical sub- unit.

Waikato May be  accompanied by the

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name of a geographical sub- unit e.g.: Ohaupo.

Coromandel Peninsula  or Coromandel

Lake Taupo 

Te Kauwhata 

Bay of Plenty May be accompanied by the  name of a geographical sub- unit e.g.: Galatea.

Gisborne May be accompanied by the name of a geographical sub- unit, e.g.: Waipaoa, Ormond,  Ormond Valley, Central Valley, Patutahi, Patutahi Plateau, Riverpoint, Manutuke, Golden Slope

Hawkes Bay or May be Hawke’s Bay accompanied by the name of a geographical sub- unit e.g.: Mohaka, Esk River, Te Awanga, Bridge Pa,  Gimblett Road, Ohiti, Dartmoor Valley, Mangatahi Terraces, Crownthorpe Terraces, Havelock Hills, Tukituki Valley.

Central Hawkes Bay or Central Hawke’s  Bay

NEW ZEALAND: WINE REGIONS NOTIFICATION TO THE WORLD WINE TRADE GROUP ELECTRONIC DEPOSITARY 1 NOVEMBER 2013

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Wairarapa May be accompanied by the name of a  geographical sub- unit e.g.: Masterton.

Gladstone 

Martinborough 

Wellington May be accompanied by the name of a  geographical sub- unit e.g. Te Horo, Kapiti, Kapiti Coast.

Marlborough May be accompanied by the name of a geographical sub-  unit e.g. Wairau or Wairau Valley, Awatere or Awatere Valley, Southern Valleys.

Nelson May be accompanied by the name of a geographical sub- unit e.g.: Golden  Bay; Motueka; Upper Moutere; Redwood Valley, Waimea Plains; Brightwater.

Canterbury May be accompanied by the name of a  geographical sub- unit e.g.: Akaroa, Banks Peninsula, West Melton.

North Canterbury May be  accompanied by the

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name of a geographical sub- unit e.g.: Weka Pass, Pyramid Valley, Cheviot Hills.

Waipara Valley or May be Waipara accompanied by the  name of a geographical sub- unit.

Waitaki Valley 

Central Otago May be accompanied by the name of a geographical sub- unit e.g.: Gibbston, Queenstown,  Wakatipu, Cromwell, Bannockburn, Bendigo, Tarras, Lowburn or Pisa, Wanaka, Alexandra, Roxburgh, Otago.

NEW ZEALAND: WINE REGIONS NOTIFICATION TO THE WORLD WINE TRADE GROUP ELECTRONIC DEPOSITARY 1 NOVEMBER 2013

NEW ZEALAND WINEGROWERS’ LABELLING GUIDE 28TH EDITION I DECEMBER 2018 37 NEW ZEALAND WINEGROWERS’ LABELLING GUIDE 30TH EDITION I FEBRUARY 2020 39 ANNEX 2 - Geographical Indications for use in Brazil

The following list sets out the geographical indications for use in Brazil. EAST COAST Northland Region, Auckland Region, Bay of The list is based on the outcomes of the 2006 industry GI survey, the Plenty Region, Coromandel District, Hauraki GI Summit of December 2008 as well as consultations with regional District, Gisborne Region, Hawkes Bay Region, associations and individuals throughout the country. Masterton District, Carterton District, South Included on the list are only those GIs that have a history of use by a Wairarapa District, Marlborough District, number of companies as “stand alone” GIs - i.e. they are not used in Canterbury Region conjunction with or subordinate to another GI. Each of these GIs has NORTH ISLAND The North Island of New Zealand clearly defined boundaries and agreement across the relevant area as Northland Northland Region to its name. Auckland Auckland Region However, exporters can still use the names of other geographical Clevedon Winegrowing area in Auckland Region 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 Western Auckland Winegrowing area in Auckland Region can still appear on the label in conjunction with a listed GI (e.g. Ohau, (comprising Henderson, Huapai, Kumeu, North Island). It also means that subordinate geographical units can Waimauku)5 appear in conjunction with a listed GI (e.g. Te Awanga, Hawkes Bay; Matakana Winegrowing area in Auckland Region Awatere Valley, Marlborough). Larger geographical units may also be Waiheke Island Waiheke Island used (e.g. Waitaki Valley, North Otago). Waikato Waikato Region

Use of geographical references Coromandel Peninsula Thames-Coromandel District

For wines bearing a geographical indication, at least 85% of the Lake Taupo Taupo District grapes from which the wine is produced must be derived from the Te Kauwhata Winegrowing area in Waikato Region stated geographical indication. Such wines must display the quality, Bay of Plenty Bay of Plenty Region reputation or other characteristics attributable to their origin. Gisborne Gisborne Region In order to use the name of a geographical unit other than a listed GI, Hawke’s Bay Hawke’s Bay Region 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 Central Hawke’s Bay Central Hawke’s Bay District least 85 % of the grapes from which the wine has been produced Wairarapa Carterton, Masterton and South Wairarapa must originate in that smaller geographical unit. The remaining Districts 15% of the grapes must be derived from the stated geographical Gladstone Defined winegrowing area In Carterton District indication. Martinborough Defined winegrowing area in Martinborough Ward

Any of the following may be considered a geographical unit/reference, Wellington Greater Wellington Region provided that they are well defined: SOUTH ISLAND The South Island of New Zealand (a) a locality or group of localities Marlborough Marlborough and Kaikoura Districts

(b) a local administrative area or part thereof Nelson Nelson and Tasman Districts

(c) a wine-growing sub-region or part thereof Canterbury Canterbury Region

(d) an administrative area North Canterbury Waimakariri and Hurunui Districts

Waipara Valley Winegrowing area in Hurunui District6 GEOGRAPHICAL DEFINED AREA Waitaki Valley Winegrowing area in Waitaki and Waimate Districts INDICATION Central Otago Central Otago and Queenstown Lakes Districts NEW ZEALAND The country of New Zealand

5 Each of these names may be used individually instead of “Western Auckland” where appropriate. 6 “Waipara” may be used as an alternative to “Waipara Valley”. ANNEX 3 - EU Allergen Declarations

40 © New Zealand Winegrowers I nzwine.com MEMBER STATE TRANSLATION

Austria German (Enthält Sulfite)

Belgium Dutch (Bevat sulfieten) English (Contains Sulphites) The following lists provide an indication based on the best information French (Contient sulfites) we have to date about the forms of allergen declaration that will be German (Enthält Sulfite) acceptable in various EU Member States. The permitted languages Cyprus Greek (Περιέχει θειώδη) and translations for the sulphites statement are provided in Annex Czech Republic Czech (Obsahuje siřičitany)

3A. The permitted languages for the milk and/or egg statement are Denmark Danish (Indeholder sulfitter) set out in Annex 3B and the permitted wording/translations in Annex Swedish (Innehåller sulfiter) 3C. The translations for the word “contains” were not officially issued Estonia Any EU language (NB Estonian = Sisaldab and are based on our previous advice on sulphite declarations. We sulfitid) encourage you to confirm the final form of your statement with your Finland Finnish (Sisältää sulfiitteja) agent. Swedish (Innehåller sulfiter). Swedish can be replaced by Danish or You can also choose to use one of the official pictograms in Norwegian. Annex 3D. The pictograms are not compulsory and must still be France French (Contient sulfites) accompanied with the “contains milk/egg” statements. English (Contains Sulphites)

Germany German (Enthält Sulfite) Annex 3A - Permitted Languages/ Greece Greek (Περιέχει θειώδη) Hungary Hungarian (Tartalmaz szulfitok) Translations (Sulphites) 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)

NEW ZEALAND WINEGROWERS’ LABELLING GUIDE 30TH EDITION I FEBRUARY 2020 41 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 Finnish and Swedish (Swedish can be replaced by Danish or Norwegian) by Danish or Norwegian) + pictogram Sweden Swedish Swedish + pictogram United Kingdom English English + pictogram

42 © New Zealand Winegrowers I nzwine.com ANNEX 3C - Permitted Wording (Sulphites/Egg/Milk)

LANGUAGE SULPHITES EGG PRODUCTS MILK PRODUCTS

Bulgarian „сулфити” or „серен „яйце”, „яйчен протеин”, „яйчен „мляко”, „млечни продукти”, диоксид” продукт”, „яйчен лизозим” or „яйчен „млечен казеин” or „млечен албумин” протеин”

Spain «sulfitos» or «dióxido de «huevo», «proteína de huevo», «leche», «productos lácteos», azufre» «ovoproducto», «lisozima de huevo» «caseína de leche» or «proteína or «ovoalbúmina» de leche»

Czech „siřičitany” or „oxid siřičitý” „vejce”, „vaječná bílkovina”, „výrobky „mléko”, „výrobky z mléka”, z vajec”, „vaječný lysozym” or „mléčný kasein” or „mléčná „vaječný albumin” bílkovina”

Danish »sulfitter« or »svovldioxid«. “æg”, “ægprotein”, “ægprodukt”, “mælk”, “mælkeprodukt”, “æglysozym”, or “ægalbumin” “mælkecasein” or “mælkeprotein”,

German „Sulfite” or „Ei”, „Eiprotein”, „Eiprodukt”, „Milch”, „Milcherzeugnis”, „Kasein „Schwefeldioxid” „Lysozym aus Ei” or „Albumin aus Ei” aus Milch” or „Milchprotein”

Estonian „sulfitid” or „vääveldioksiid” „muna”, „munaproteiin”, „piim”, „piimatooted”, „munatooted”, „munalüsosüüm” or „piimakaseiin” or „piimaproteiin” „munaalbumiin”…

Greek «θειώδη», «διοξείδιο του «αυγό», «πρωτεΐνη αυγού», «προϊόν «γάλα», «προϊόντα γάλακτος», θείου» or «ανυδρίτης του αυγού», «λυσοζύμη αυγού» or «καζεΐνη γάλακτος» or «πρωτεΐνη θειώδους οξέος» «αλβουμίνη αυγού» γάλακτος»

English ‘sulphites’, ‘sulfites’, ‘egg’, ‘egg protein’, ‘egg product’, ‘milk’, ‘milk products’, ‘milk ‘sulphur dioxide’ or ‘sulfur ‘egg lysozyme’ or ‘egg albumin’ casein’ or ‘milk protein’ dioxide’

French «sulfites» or «anhydride «œuf», «protéine de l’œuf», «produit «lait», «produits du lait», «caséine sulfureux» de l’œuf», «lysozyme de l’œuf » or du lait» or «protéine du lait» «albumine de l’œuf»

Italian «solfiti», or «anidride «uovo», «proteina dell’uovo», «latte», «derivati del latte», solforosa» «derivati dell’uovo», «lisozima da «caseina del latte» or «proteina uovo» or «ovoalbumina» del latte»

Latvian „sulfīti” or „sēra dioksīds” „olas”, „olu olbaltumviela”, „olu „piens”, „piena produkts”, „piena produkts”, „olu lizocīms” or „olu kazeīns” or „piena olbaltumviela” albumīns”

Lithuanian „sulfitai” or „sieros „kiaušiniai”, „kiaušinių baltymai”, „pienas”, „pieno produktai”, dioksidas” „kiaušinių produktai”, „kiaušinių „pieno kazeinas” or „pieno lizocimas” or „kiaušinių albuminas” baltymai”

Hungarian „szulfitok” or „kén-dioxid” „tojás”, „tojásból származó fehérje”, „tej”, „tejtermékek”, „tejkazein” „tojástermék”, „tojásból származó or „tejfehérje” lizozim” or „tojásból származó albumin”

LANGUAGE SULPHITES EGG PRODUCTS MILK PRODUCTS

Dutch “sulfieten” or “ei”, “eiproteïne”, “eiderivaat”, “melk”, “melkderivaat”, “zwaveldioxide” “eilysozym” or “eialbumine” “melkcaseïne” or “melkproteïnen”

NEW ZEALAND WINEGROWERS’ LABELLING GUIDE 30TH EDITION I FEBRUARY 2020 43 ANNEX 3C - Permitted Wording (Sulphites/Egg/Milk) cont.

Polish „siarczyny”, „dwutlenek “jajo”, “białko jaja”, „produkty z jaj”, “mleko”, “produkty mleczne”, siarki” or „ditlenek siarki” “lizozym z jaja” or “albuminę z jaja” “kazeinę z mleka” or “białko mleka”

Portuguese «sulfitos» or «dióxido de «ovo», «proteína de ovo», «produto «leite», «produtos de leite», enxofre» de ovo», «lisozima de ovo» or «caseína de leite» or «proteína de «albumina de ovo» leite»

Romanian „sulfiți” or „dioxid de sulf” „oră”, „proteine din oră”, „produse din „lapte”, „produse din lapte”, oră”, „lizozimă din oră” or „albumină „cazeină din lapte” or „proteine din oră” din lapte”

Slovakian „siričitany” or „oxid siričitý” „vajce”, „vaječná bielkovina”, „mlieko”, „výrobky z mlieka”, „výrobok z vajec”, „vaječný lyzozým” „mliečne výrobky”, „mliečny or „vaječný albumín” kazeín” or „mliečna bielkovina”

Slovenian ‘sulfit’ or ‘žveplov dioksid’ ‘jajce’, ‘jajčne beljakovine’, ‘proizvod ‘mleko’, ‘proizvod iz mleka’, iz jajc’, ‘jajčni lizozim’ or ‘jajčni ‘mlečni kazein’ or ‘mlečne albumin’ beljakovine’

Finnish ‘sulfiittia’, ’sulfiitteja’ or ‘kananmunaa’, ‘kananmunaproteiinia’, ‘maitoa’, ’maitotuotteita’, ‘kaseiinia ’rikkidioksidia’ ’kananmunatuotetta’, ‘lysotsyymiä (maidosta)’ or ‘maitoproteiinia’ (kananmunasta)’ or ’kananmuna- albumiinia’

Swedish “sulfiter” or “svaveldioxid” “ägg”, “äggprotein”, “äggprodukt”, “mjölk”, “mjölkprodukter”, “ägglysozym” or “äggalbumin” “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: Grape wine made effervescent with carbon dioxide resulting solely from the ‘‘sparkling wine,’’ fermentation of the wine within a closed container, tank or bottle. ‘‘sparkling red wine’’ & ‘‘sparkling white wine’’

CARBONATED GRAPE WINE Includes: Grape wine made effervescent with carbon dioxide other than that resulting solely ‘‘carbonated wine,’’ ‘‘carbonated red wine,’’ & from the secondary fermentation of the wine within a closed container, tank or bottle. ‘‘carbonated white wine’’

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).

44 © New Zealand Winegrowers I nzwine.com EU The EU regulations provide the following definitions for the category of sparkling wine:

SPARKLING QUALITY QUALITY AERATED SEMI-SPARKLING AERATED SEMI- WINE SPARKLING WINE AROMATIC SPARKLING WINE SPARKLING WINE SPARKLING WINE WINE

Is obtained by first Is obtained by first Is obtained only by is obtained from wine Is obtained from Is obtained from wine or second alcoholic or second alcoholic making use, when without a protected wine provided that fermentation from fermentation from fresh constituting the cuvée, designation of origin such wine has a total fresh grapes, grape grapes, grape must of grape must or grape or a geographical alcoholic strength of must and/or wine and/or wine must in fermentation indication not less than 9 % vol 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)

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

Has an excess Has an excess pressure, Has an excess pressure, Has an excess Has an excess Has an excess pressure pressure, due to due to carbon dioxide due to carbon dioxide pressure, due to pressure, due to of not less than 1 bar carbon dioxide in in solution, of not less in solution, of not less carbon dioxide in endogenous carbon and not more than 2,5 solution, of not less than 3 bar when kept at than 3 bar when kept at solution, of not less dioxide in solution of bar when kept at a than 3 bar when kept a temperature of a temperature of than 3 bar when kept not less than 1 bar temperature of 20 oC in at a temperature of 20 oC in closed 20 oC in closed at a temperature of and not more than 2,5 closed containers due 20 oC in closed containers; and containers; and 20 oC in closed bar when kept at a to carbon dioxide in o containers; and containers temperature of 20 C solution which has been in closed containers wholly or partially added

The total alco- The total alcoholic The actual alcoholic Has an actual alcoholic Has an actual alcoholic holic strength of the strength of the cuvées strength may not be strength of not less strength of not less cuvées intended for intended for their less than 6 % vol and than 7 % vol; and than 7 % vol. and a their preparation preparation shall not be the total alcoholic total alcoholic strength shall not be less than less than 9 % vol strength may not be of not less than 9 % 8.5 % vol less than 10 % vol vol; and

Is put up in containers Is put up in containers of 60 litres or less of 60 litres or less

When meeting the EU “category of grapevine product” requirement, In addition to the standard labelling requirements, all categories of producers must comply with these definitions. sparkling wine (except for semi-sparkling and aerated semi-sparkling) If the wine is an aerated sparkling wine for the purposes of the must include: definitions listed above, the label must state “obtained by adding a) an indication of sugar content (see below); and carbon dioxide” or “obtained by adding carbon anhydride” b) the producer/vendor address rather than the mandatory bottler underneath the product description (ie. “aerated sparkling wine”) in address. the same type and size.

NEW ZEALAND WINEGROWERS’ LABELLING GUIDE 30TH EDITION I FEBRUARY 2020 45 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 If its sugar content is less than 3 grams per litre; these terms

wytrawne, брютzéro, natūralusis briutas, īsts bruts, přírodně may be used only for products to which no sugar has been , tvrdé, popolnoma suho, dosaggio zero, брют натюр brut natur added after the secondary fermentation. extra brut, extra herb, ekstra briutas, ekstra brut, ekstra bruts, If its sugar content is between 0 and 6 grams per litre.

zvláště tvrdé, extra bruto, izredno suho, ekstra wytrawne, екстра брют brut, herb, briutas, bruts, tvrdé, bruto, zelo suho, bardzo If its sugar content is less than 12 grams per litre.

wytrawne, брют extra dry, extra trocken, extra seco, labai sausas, ekstra kuiv, If its sugar content is between 12 and 17 grams per litre. ekstra sausais, különlegesen száraz, wytrawne, suho, zvláště , suché, extra suché, екстра сухо extra sec, ekstra tør , sec, trocken, secco, asciutto, dry, tør, ξηρός seco, torr, kuiva, If its sugar content is between 17 and 32 grams per litre.

sausas, kuiv, sausais, száraz, półwytrawne, polsuho, suché, сухо demi-sec, halbtrocken, abboccato, medium dry, If its sugar content is between 32 and 50 grams per litre. , halvtør, ημίξηρος semi seco, meio seco, halvtorr, puolikuiva, pusiau sausas, poolkuiv, pussausais, félszáraz, półsłodkie, polsladko, polosuché,

polosladké, полусухо , doux, mild, dolce, sweet, sød, γλυκός dulce, doce, söt, makea, If its sugar content is greater than 50 grams per litre. , saldus, magus, édes, ħelu, słodkie, sladko, sladké, сладко dulce, saldais

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 May only be used to describe wines with protected designations of origin or with a GI of a third country or quality sparkling traditional method” or wine if it: “traditional method” or (a) was made sparkling by a second alcoholic fermentation in the bottle; “classical method” or “classical (b) stayed without interruption in contact with the lees for at least nine months in the same undertaking from the time traditional method” when the cuvée was constituted; (c) was separated from the lees by disgorging. “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) 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 geographical indication of a third country in question.

46 © New Zealand Winegrowers I nzwine.com 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 or equal to 0.35 MPa at 20oC (for bottles with a capacity of less than 250 ml, 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 Aerated wines with carbon dioxide (completely caused by natural fermentation) pressure within the range of 0.05-0.34 WINE 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’ LABELLING GUIDE 30TH EDITION I FEBRUARY 2020 47 ANNEX 5 –Representations of origin for wines sold in New Zealand

Representations of origin for wines sold in New Zealand

All wine sold in New Zealand must be labelled with its country of origin. Many wines choose to highlight their regional origin as well. The law requires that any claims made about a wine’s origin must not be false, misleading or deceptive.

WHAT THE LAW SAYS The origin of a wine is usually one of The three most important laws about using its most distinguishing features and representations of origin on your wine and consumers are often influenced by a marketing in New Zealand are: wine’s origin when deciding what to buy. That’s why most bottles of New Zealand Section 13(j) of the Fair Trading Act 1986 wine proudly proclaim their origin in one says: way or another – eg: - “no person shall… …make a false or - with words – “Wine of New Zealand”; misleading representation concerning “Central Otago Pinot Noir”; “Awatere the place of origin of goods.” Valley, Marlborough” Regulation 7 of the Wine Regulations - with images or branding – a map 2007 says: showing the place; a flag; an emblem; - all grape wine sold in New Zealand an image of a notable local feature like “must be labelled in a manner that a river, hill, or building; or some other clearly indicates the country of origin of design or logo that in the consumer’s the wine”; and mind will be associated with a place. - if any of the grape content comes from another country “that country must All of these things can be representations be named on the label as a source of of origin – something that tends to make ingredients used in the manufacture of a consumer associate your wine with a the wine”. place. This factsheet summarises the law around representations of origin and Section 21 of the Geographical Indications gives some guidance on how to apply the (Wine and Spirits) Registration Act 2006 law to your wine. says: A person may use a New Zealand registered geographical indication in Our New Zealand Winegrowers Labelling relation to a wine only if: Guide (pages 5 - 10) discusses in detail all of the mandatory labelling requirements, - at least 85% of the wine is obtained plus requirements that apply only when from grapes harvested in that place (or you include optional information like places); and vintage and variety. - all of the rest of the wine is obtained from grapes harvested in New Zealand.

This factsheet is only for guidance, and is not legal advice. If you have any concern that your packaging may be false, misleading or deceptive, you should seek legal advice. February 2018

48 © New Zealand Winegrowers I nzwine.com The penalties for breach of the Fair Trading Act and the Geographical Indications Act are WHAT INFLUENCES A REASONABLE significant – up to $600,000 per breach – and CONSUMER? the surrounding publicity can destroy a brand. The whole impression a consumer takes Breach of the Wine Regulations with intent to from your packaging might be influenced deceive is an offence for which the maximum by things like: penalty includes imprisonment. Size and placement of the elements: Other laws also impose similar requirements - What is prominent (big, bold, clear, – for example section 238(2) of the Food Act high-contrast, placed where it will be 2014 and section 97(1)(b) of the Wine Act seen easily)? 2003. - What do you only notice if you look carefully (small, indistinct, low contrast, HOW DO I KNOW IF MY buried within blocks of text?) REPRESENTATIONS OF ORIGIN ARE MISLEADING UNDER THE FAIR TRADING Completeness: What is omitted from ACT? the packaging that might change the consumer’s impression? The law gives you a lot of flexibility about how you label your wine for sale Clarity: Is it easy to understand the in New Zealand, and how you promote it elements of information presented? in your advertising and marketing. But it also requires you to be straight-up with Consistency: Are there disparities consumers so that if they are thinking of between different elements, or does buying your wine, your representations the information consistently steer the of origin leave them with a fair and consumer towards the same accurate accurate impression of where the wine impression? is from. If you start by thinking of it as a - For example, does the main branding requirement to “be honest, and respect and imagery all suggest “New Zealand”, your consumers”, you’ll be 90% of the while the “country of origin” statement way there. in small type within a large panel of text Because each product and its packaging says “Wine of Australia”? and marketing is different it is impossible Inferences: to give many hard and fast rules. But an important part of the test includes asking Does the label echo a well-known label? whether or not a reasonable consumer, in Does a “made-up” landscape look like a all the circumstances, would be misled. real place? Whether you intended to mislead is irrelevant. Does the brand name include or suggest a place name? (eg Maori words will This means you need to think about likely suggest “New Zealand”); the whole impression conveyed to the consumer by your product and its Is the “producer address” a place known marketing, including its wording, images, for its wine, even though the wine in and branding; plus what the consumer the container is from elsewhere? (eg a might already know about it. You also Sauvignon Blanc grown in Bay of Plenty particularly need to think about how but with a Blenheim producer address). prominent (or hard-to-find) different pieces of information are. All of these Familiarity: things will influence the whole impression Is this a new brand or labelling, or is it that a consumer will get – and whether or old and familiar? not they may be misled.

This factsheet is only for guidance, and is not legal advice. If you have any concern that your packaging may be false, misleading or deceptive, you should seek legal advice. February 2018

NEW ZEALAND WINEGROWERS’ LABELLING GUIDE 30TH EDITION I FEBRUARY 2020 49 Does it look like something familiar, but WINE SOLD OUTSIDE NEW ZEALAND is actually something different? (eg has the wine composition changed since It is important to note that the last vintage, and if so is that clear?) information in this factsheet applies to wine sold in New Zealand. Labelling Purchase setting: How many seconds requirements for wine sold outside New might the customer spend at the Zealand is determined by the laws of supermarket shelf before selecting each market of sale. In this regard the your wine? passage of the GI Act has made clear that under USA law, NZ wine sold in the All of these factors, and more, will USA and labelled with a registered NZ influence whether the representations Geographical Indication must be 100% of origin made by your wine, when New Zealand wine. taken as a whole, might be found to be misleading.

If there is some element of your WHERE CAN I GET MORE INFORMATION? packaging that might give a misleading impression (but which for some reason Our New Zealand Winegrowers Labelling is important to retain) you should ensure Guide contains detailed guidance on all that the accurate information is also aspects of labelling. presented, and is much more prominent The Commerce Commission has produced so it will be immediately obvious to a a guide to prospective customer. In this situation, Fair Trading Act Place of Origin (which focusses on “Made you should seek legal advice. Representations in New Zealand” type claims).

For more information, or to discuss your IMPACT OF THE GEOGRAPHICAL labelling compliance generally, contact the INDICATIONS ACT New Zealand Winegrowers Advocacy team: [email protected] The Geographical Indications (Wine and Spirits) Registration Act adds an additional restriction.

For any registered Geographical Indication, you may not use the registered words – even as part of a brand name – if the wine is not from that region.

For example: a wine branded “Gisborne Hills”, made from less than 85% Gisborne grapes would not be permitted, because “Gisborne” is a registered GI for wine.1 The GI Act also reiterates that a wine may only bear a registered New Zealand GI if all of the grapes used are New Zealand grapes.

1 Note that some exceptions apply for trademarks that existed before the GI was registered.

This factsheet is only for guidance, and is not legal advice. If you have any concern that your packaging may be false, misleading or deceptive, you should seek legal advice. February 2018

50 © New Zealand Winegrowers I nzwine.com ANNEX 6 – Portman Group Guidance Appendix A In September 2017 the Portman Group released new guidance for the voluntary industry approach to communicating alcohol and health-related information on packaging of wine sold in the AppendixUK. The full guidance A can be downloaded from: portmangroup.org.uk. The suggested labels and icons are reproduced below. Note that inclusion of the drinkaware.co.uk web address requires a licence from drinkaware. CONTENT FOR PACKAGING

CONTENT FOR PACKAGING

Or: “It is safest Units must 1 be displayed For further health not to drink per container, information visit alcohol when as Unitsand optionally must Or:pregnant”“It is safest Per1 an alternative beper displayed serve. For further health not to drink 25ml to logo. per container, information visit alcohol when pregnant” as and optionally Per per serve. an alternative 25ml to logo. Example label presenting the minimum elements on-pack with active signpost to Drinkaware.co.uk.

Example label presenting the minimum elements on-pack with active signpost to Drinkaware.co.uk.

Or: “It is safest Units must The UK Chief Medical Officers 1 not to drink be displayed recommend adults do not alcohol when per container, regularly drink more Or:pregnant”“It is safestas Unitsand optionally must Thethan UK 14 Chiefunits Medicalper week. Officers Per1 notan alternativeto drink beper displayed serve. recommend adults do not 25ml alcoholto logo. when per container, regularly drink more pregnant” as and optionally than 14 units per week. Per an alternative per serve. 25ml to logo. Example label featuring CMOs’ Low Risk Drinking Guidelines.

Example label featuring CMOs’ Low Risk Drinking Guidelines.

For further health 1 information visit

For further health Per1 information visit 25ml

Per 25ml

For further health 1 information visit

For further health Per1 information visit 25ml

Per 25ml Example labels featuring minumum elements and other icons.

© New Zealand Winegrowers Example labels featuring minumum elements and other icons. November 2019 7

NEW ZEALAND WINEGROWERS’ LABELLING GUIDE 30TH EDITION I FEBRUARY 2020 51 7 nzwine.com