Labelling guide New Zealand Winegrowers - 26th Edition | April 2017 - Wine Marlborough
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New Zealand
Winegrowers
labelling
guide
26th Edition | April 2017
nzwine.com
New Zealand
Winegrowers
labelling
guide
26th Edition | April 2017
www.nzwine.com
Follow on Twitter #nzwine, @nzwine
facebook.com/newzealandwinegrowers
Cover image courtesy of Pegasus BayINTRODUCTION
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.
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 jeffrey@nzwine.com or Silua Ettles on Silua.ettles@nzwine.com for further assistance.
CHANGES IN THIS 26th EDITION
Where substantive changes have been made since the last edition of the Labelling Guide, the text is shaded yellow.
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 Material may not be published or reproduced without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 March 2017, 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.
NEW ZEALAND WINEGROWERS’ LABELLING GUIDE 26th EDITION I March 2017 1TABLE OF CONTENTS
DESIGNING A WINE LABEL: THE BASICS 3 RUSSIA
NEW ZEALAND Russian labelling laws 28
New Zealand labelling laws 5 Mandatory information 28
Optional Information 29
Mandatory Information 5
Optional information 6 BRAZIL
What else you should know 9 Brazilian labelling laws 30
Mandatory information 30
AUSTRALIA
OTHER ASIAN ECONOMIES
Australian labelling laws 11
Hong Kong 31
Mandatory Information 11
Thailand 31
Optional information 11
Malaysia 31
EUROPEAN UNION (EU) Singapore 31
EU labelling laws 12
India 32
Mandatory information 12
Taiwan 32
Optional information 14
Philippines 32
UNITED STATES OF AMERICA Indonesia 33
United States labelling laws 17
ANNEX 1
Mandatory information 17 Appellations of origin for use in the USA 34
Optional information 18
ANNEX 2
CANADA Geographical Indications for use in the EU and Brazil 39
Canadian labelling laws 20 Annex 3
Mandatory information 20 EU Allergen Declarations 40
Optional information 21 Annex 3A
40
Permitted Languages/Translations (Sulphites)
CHINA
Chinese labelling laws 23 Annex 3B
Mandatory information 23 Permitted Languages (Milk/Egg) 41
Optional information 24 Annex 3C
Permitted Wording (Sulphites/Egg/Milk) 42
JAPAN
Japanese labelling laws 25 Annex 3D
43
Mandatory information 25 Pictograms (Sulphites/Egg/Milk)
Optional information 25 Annex 4
Sparkling Wine 43
SOUTH KOREA
USA 43
South Korea’s labelling laws 26
EU 44
Mandatory information 26
China 46
Optional information 27
2 © New Zealand Winegrowers I nzwine.comDESIGNING A WINE LABEL: THE BASICS
When you are designing labels for a wine that will be sold in multiple markets, there are 5 key points to keep in mind:
1. You can design a single front label that will work for most major markets
2. You will need to change your back label for each different market (except Australia)
3. For some markets, you will need a special language label
4. For vintage, variety and geographical indication, the most restrictive rules apply
5. Special wines have special rules
1. THE SINGLE FRONT LABEL
There are two options for a front label that can be used in all major markets:
The “clean” front label
You can meet all of you legal mandatory information requirements on the back label, leaving the front label “clean”.
Clean front label Legal back label (NZ/AUS)
John’s
JOHN’S WINERY
52 SYMONDS STREET
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 JOHN’S WINERY
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
NEW ZEALAND WINEGROWERS’ LABELLING GUIDE 26th EDITION I March 2017 32. 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
Why? Because every country requires that the impor ter in
if an export market has more restrictive rules than NZ, you must
their territory is listed on the label to ensure traceability. Plus,
follow those rules as well as the NZ rules.
most countries will have their own unique requirements which
aren’t compatible with other countries – like NZ’s standard The only exception is a single grape variety statement in the
drinks requirement. USA 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. 5. SPECIAL WINES HAVE SPECIAL RULES
Others have tried to list the importers for each different market on
the same label, but this takes up space and doesn’t get you into Sweet wines, sparkling wines, fortified wines, wines with high alcohol,
very many markets. wines in non-standard packages – all of these may be subject to
special labelling rules. These may include:
3. SPECIAL LANGUAGE LABELS • special names that must be used on the label
• additional mandatory information such as sweetness level
Some markets like China, Japan and Russia require the label to be
presented in local characters. Canada requires some information • different type size requirements
to be presented in French and English. In these cases, it is best The Labelling Matrix covers standard wines in a 750ml bottle
to produce a special label for the market. This should be done in only so you should not rely on it when labelling special wines.
consultation with your local distributor or importer to make sure you You will need to consult the Labelling Guide and possibly also the
get it right. Winemaking Practices Guide when labelling these products.
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 jeffrey@nzwine.com or Silua Ettles on Silua.ettles@nzwine.com
if you have any questions.
4 © New Zealand Winegrowers I nzwine.comNEW ZEALAND
NEW ZEALAND LABELLING LAWS Alcohol by volume
The main laws governing the labelling of wine for sale in New A wine label must include an alcohol declaration (Standard 2.7.1).
Zealand 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 1981/2014
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
• Fair Trading Act 1986
A wine label must include a statement of the net contents,
expressed as litres, decilitres, centilitres or millilitres (e.g. 750 ml).
• Sale and Supply of Alcohol Act 2012
This 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
information portal www.foodsafety.govt.nz • placed in a prominent position in close proximity to the name
of 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 website address. Note that the person named on the label is
true nature of the food (Standard 1.2.2). For wine, this can be: presumed to be responsible for the product and will be legally liable
• the word “wine” for that product under the Food Act 1981/2014.
• the type of wine (e.g. “sparkling wine”, “white wine” etc) Sulphite declaration
• a variety name
A wine label must include a sulphite declaration if it contains more
• a generic name such as Port than 10 mg/kg of sulphur dioxide. The form of the statement is:
“contains preservative 220”, “contains sulphites”, or “contains
Country of origin sulphur dioxide”. This is not a “warning statement” in terms
A wine label must include a statement indicating the country of of the Food Standards Code, and the type size requirements
origin (e.g. “New Zealand wine”, “Product of New Zealand”) (r. 7 therefore do not apply.
of the Wine Regulations 2006). If any of the grapes, grape juice,
Allergen declaration
concentrated grape juice or spirit used in a wine originates in
another country, then that must also be included on the label - i.e. A wine label must include an allergen declaration if milk,
you cannot use imported concentrated grape juice unless you are milk products, egg, egg products, fish products (except for
prepared to acknowledge it in the country of origin statement. See isinglass) or other allergens 1 are present (Standard 1.2.3).
the note below on Representations of Origin. Isinglass is exempted from this requirement.
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 26th EDITION I March 2017 5Testing for milk and egg residues in wine is now available in New • more than 10 standard drinks then the statement of the
Zealand. Each winery must make their own commercial decision number of standard drinks must be accurate to the nearest
about whether or not to label for the presence of allergens, whole number
based on their confidence that allergens are not present. In some The form of the standard drink statement is: “contains approx. x.x
countries, a ‘not detected’ result (using a method of detection with standard drinks”. The word ‘approximately’ may be spelt in full if desired.
a 0.25ppm limit of detection) is considered a confirmation that
Standard drinks can be calculated on the labelled alcoholic content
allergens are “not present”. MPI’s view is that if processing aids
of the wine. The formula for calculating the number of standard
containing allergens have been used in production, a test result
drinks is: 0.789 x the alcohol content x the volume of the
showing that allergenic protein is ‘not detected’ is not confirmation
container (in litres).
that no allergenic protein is present. However, if
So for a wine with a labelled alcohol content of 12% in a 750 ml
• You follow good manufacturing practice (for fining there are
bottle the formula is: 0.789 x 12 x 0.75 = 7.1.
some recommendations issued by the OIV)
• You have a statistical process control programme in place for Lot identification
sampling and testing your wines for the presence of allergens A wine label must include lot identification on the label or bottle
which could demonstrate that a given wine would return a ‘not (Standard 1.2.2). However, if there is just one bottling run for a
detected’ result, and particular wine then there is no need to include a lot number, as the
• You keep all records and documentation of your use of lot’s identification is self-defined.
allergenic processing aids, statistical process control
programme and analytical results in your wine standards OPTIONAL INFORMATION
management plan WSMP. General provisions
then you will have a good, sound basis on which to take the In addition to the mandatory items, there are also some general
commercial decision not to label for the presence of allergens. provisions it is necessary to note. Wine labels cannot:
The form of the labelling requirement is not specified in legislation. • bear health claims
The following forms of declaration were suggested in legal advice • encourage or be likely to encourage excessive consumption
from Bell Gully: • be aimed at or be likely to have special appeal for minors
• “[Milk/Egg] products have been used as a fining agent in the • make representations as to being low in alcohol or non-
manufacture of this wine. Traces may remain.” intoxicating or
• “Fining agent: [milk/egg] products.” • be false or liable to mislead or deceive consumers
• “[Milk/Egg] products have been used to purify this wine, in The Sale and Supply of Alcohol Act 2012 includes a number of
accordance with traditional winemaking techniques. Traces restrictions on advertising and promotion of alcoholic beverages
may remain.” that may impact on wine labelling. The Health Promotion Agency has
The following additional forms of declaration were developed by the produced guidance on these requirements that can be found online
Australian Wine and Brandy Corporation in consultation with Food here.
Standards Australia New Zealand. If exporting to Australia, it may The Advertising Standards Authority’s “Code for Advertising
be preferable to use these forms: and Promotion of Alcohol” and the Fair Trading Act provide
• “Produced with casein (milk product)” further guidance in this regard.
• “Contains/produced with milk product”
Fair Trading Act 1986
• “Produced with casein (milk product). Traces may remain”
All information on a wine label (as well as any other material used to
• “Produced with milk products. Traces may remain”
present or describe a wine) is subject to the Fair Trading Act 1986,
Standard drinks which prohibits misleading or deceptive conduct in trade, conduct
that is liable to mislead in respect of goods, and false or misleading
A wine label must include a standard drinks declaration (Standard
representations as to the quality, grade, composition, style or
2.7.1). A standard drink is the amount of wine containing 10 grams
nature of products. The New Zealand Winegrowers Legal
of ethanol measured at 20° C.
Guide provides useful guidance in relation to the Fair Trading
If the product contains: Act. Note that misleading or deceptive conduct or representations
• less than 10 standard drinks, the statement of the number of relating to goods supplied from New Zealand to China will be an
standard drinks must be accurate to 1 decimal place offence under the Fair Trading Act and may authorise a search
warrant being issued in New Zealand.
6 © New Zealand Winegrowers I nzwine.comUnder the Fair Trading Act, it is also an offence to make an • An exemption applies to wines made from or containing wine from
unsubstantiated representation in trade. A representation is the 2006 vintage. Contact NZW if you require further information.
unsubstantiated if the person making the representation does not, The Geographical Indications (Wine and Spirits) Registration
when the representation is made, have reasonable grounds for the Amendment Act 2016 will come into force in 2017. This will not
representation, irrespective of whether the representation is false change any of the above requirements regarding grape variety,
or misleading. This could include such matters as a representation vintage and geographical indication.
of organic or sustainable status for products that are not certified
as having such status. Note that representations that a reasonable Representations of origin
person would not expect to be substantiated are exempted from Features of a label such as a geographical brand name, Maori
this requirement. imagery/wording, business description/address or pictorial
representations of a geographic location can combine to imply the
Grape variety, vintage and geographical indication: the 85% rule
New Zealand or regional origin of a product. Where the combined
From vintage 2007, the following rules for label claims covering effect of a product’s packaging implies a specific geographical
grape variety, vintage and the area where the grapes were grown origin which is not accurate in terms of the product’s composition,
(other than the country of origin) apply: wineries should take steps to ensure that the correct origin of
• single variety, vintage or area: at least 85% from the the product is immediately obvious to any prospective purchaser
stated variety, vintage or area. For example, if a label says or risk breaching the Fair Trading Act. It may not be suffcient to
the wine is ‘2007’, at least 85% of that wine must be from simply include an origin statement in small font on the back label.
the 2007 vintage Strict adherence to wine-specific regulations such as the origin
• blends: at least 85% of the blend must be from the stated standards in the Australia New Zealand Food Standards Code or
varieties, vintages or areas. For example, if the wine label the composition requirements contained in the Wine (Specifictions)
says ‘Chardonnay Chenin Blanc, then at least 85% of that Notice 2006 (the 85% rule) is not a defence to a breach of the Fair
wine must have been made from Chardonnay and Chenin Trading Act.
Blanc grapes
Cabernet
• combination claims: the combination referred to must be at
MPI has advised that:
least 85% of that wine. For example, if a label states that the
wine is a ‘2008 Marlborough Pinot Noir’, then 85% of the • it is acceptable to use “Cabernet” as a synonym for Cabernet
wine must be from Pinot Noir grapes grown in Marlborough in Sauvignon but not for Cabernet Franc or a combination of
the 2008 vintage those two varieties
• where a label refers to more than one grape variety, more • if Cabernet Franc is part of a wine label claim about grape
than one vintage, or more than one geographic area, these varieties, it must be named in full
must be presented in descending order of proportion in the
Sauvignon Gris
blend. Using the ‘Chardonnay Chenin Blanc’ example above, as
well needing to meet the 85% rule, there must be a greater “Sauvignon Gris” is a statement regarding a single grape variety
proportion of Chardonnay than Chenin Blanc in the blend (not a blend of Sauvignon Blanc and Pinot Gris). The 85% rule
therefore applies so that if a wine is labelled “Sauvignon Gris”, then
• A label must not include a claim about grape variety, vintage
at least 85% of that wine must have been made from Sauvignon
or area of origin if that wine contains a greater percentage
Gris grapes.
of wine from another grape variety, vintage or area of origin
that is not referred to by that label. For example, a wine that Moscato
contains 75% Cabernet Sauvignon, 15% Pinotage and 10% MPI has advised that “Moscato” (or “Muscato”) is a varietal
Merlot could be referred to as a ‘Cabernet Pinotage’ or a descriptor and can therefore only be used where at least 85% of the
‘Cabernet Pinotage 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
fortifying wine 'Single vineyard' and similar statements
• The use of concentrated grape juice as a sweetener is excluded Some wine labels bear statements that create the impression
from the 85% region, variety, vintage calculations. This exclusion that the wine is made from grapes that are exclusively grown in
does not apply to the country of origin statement a specific vineyard (e.g. “single vineyard” followed by a vineyard
NEW ZEALAND WINEGROWERS’ LABELLING GUIDE 26th EDITION I March 2017 7name) or produced in a particular way (e.g. "hand picked"). Where disease, disorder or condition. This would include, for example, claims
such terms are used, NZW’s view is that the grapes should be that certain properties or components of wine have protective effects
exclusively sourced from the named vineyard or produced in the on heart health.
specified way in order to avoid creating a misleading impression. MPI have guidance on the use of such claims on their website:
www.foodsafety.govt.nz
Exports
The 85% rule is now a benchmark minimum content for all New Nutrition content
Zealand wine, whether sold domestically or exported. This means It is no longer permitted to make a nutrition content claim other
that, in principle, all wine made from 2007 onwards and exported than an energy content (calorie), carbohydrate content or gluten
from New Zealand must be made in accordance with the 85% rule content claim on the label of an alcoholic beverage containing more
above, subject to the following: than 1.15% alcohol by volume.
• if the overseas market has a stricter labelling requirement, the A nutrition content claim is defined as a claim that is made about:
overseas market requirement must be complied with.
• the presence or absence of energy (eg. calories or kj), a
• if the overseas market has a less strict requirement and biologically active substance, dietary fibre, minerals, potassium,
MPI has given specific permission for exporters to use the less protein, carbohydrate, fat, salt, sodium or vitamins; or
strict requirement applying in that market, then the less strict
• glycaemic index or glycaemic load,
requirement is available to exporters.
that does not refer to the presence of alcohol and is not a health
Environmental, sustainability and organic claims claim. A “gluten free” claim counts as a nutrition content claim.
The Commerce Commission requires that “Businesses making There are no stock-in-trade provisions, so we recommend that all
environmental claims - including statements about sustainability, new labels comply with this requirement.
recycling, carbon neutrality, energy efficiency, use of natural
Nutrition content claims
products or impact on animals and the natural environment -
should ensure those claims are accurate, scientifically sound If you want to make a nutrition content claim, use the flow chart
and substantiated.” As above, such substantiation is now a below to check whether it is permitted. If permitted, be sure
requirement under the Fair Trading Act. New Zealand Winegrowers to follow the relevant detailed requirements. Note that this is a
recommendation is that all such claims should be substantiated by summary. A complete guide is available at
current full certification to an appropriate third party scheme. www.foodstandards.govt.nz
New Zealand Winegrowers provides detailed guidance on the use of
environmental, sustainability and organic claims in the New Zealand
Is the claim about: STOP!
Winegrowers Code of Practice for Environmental Claims available at Energy, Carbohydrates
www.nzwine.com. or Gluten? N you cannot make the claim
In order to use the Sustainable Winegrowing New Zealand (SWNZ) Y
logo, permission must be granted by the SWNZ Business Manager.
Permission is only granted under the following circumstances and is
Have you made a Y
at the discretion of SWNZ: Gluten Free claim?
• the wine company registered with NZW must be a SWNZ Tier 3 member
N
• the wine must be made from 100% accredited vineyard grapes
• the wine must be wholly produced in accredited winery facilities Include a
Nutritional Information
• the SWNZ logo rules are fully complied with panel
For further information please contact membership@swnz.org.nz.
Health Claims Is it a comparative N
Health claims are not permitted on the label of an alcoholic beverage. claim? e.g. 'lighter in
energy, lower in carbs'
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 Y
the human body, including an effect on one or more of the following:
Mention the reference product. You can make these
a biochemical, physiological, functional process or outcome, growth Reduction must be at least
and development, physical performance, mental performance and a statements or claims
25% lower than reference.
8 © New Zealand Winegrowers I nzwine.comPermitted energy content or carboydrate claims Health advisory information/Pregnancy labelling
In order to make an energy or carbohydrate content claim under Wineries are encouraged to promote safe and responsible
Standard 1.2.7 the following elements must be included on the label: consumption on their wine labels. NZW recommends that members
1. A nutritional information panel (NIP) (standard 1.2.8); include a pregnancy health advisory statement on the labels of all
wine sold in New Zealand. This may take the form of either a written
2. If a comparative claim is made (e.g. ‘reduced calorie’,
message indicating that the safest option for pregnant women is not
'lighter', ‘reduced carbohydrate’ or similar terms) the claim
to drink or the pregnancy advisory logo. The government is closely
must include:
watching to see an increase in voluntary use of pregnancy labelling.
a) the identity of the reference food and
If use does not increase, mandatory preganacy labelling is likely to
b) the difference between the amount of the property of
be impossed. Wineries can download this logo via nzwine.com/
food in the claimed food and the reference food. For example:
members/advocacy and click into ‘Social Responsibility’’
“Reduced calorie wine - at least 25% less calories compared to
the standard [X Brand] Sauvignon Blanc 2013.”
3. Terms such as “reduced”, “lighter” or their synonyms will only
be permitted where the reduction in content is at least 25%
compared to the reference product.
A NIP is not required for a gluten free claim.
Cheers!
Lower alcohol claims Wineries are also encouraged to use the Cheers! logo as a way of
The Australia New Zealand Food Standards Code prohibits any product driving consumers towards the www.cheers.org.nz website where
containing more than 1.15% alcohol from being represented as a "low" useful information on safe and responsible drinking can be found.
alcohol beverage. In addition, the Advertising Standards Authority Code To use the Cheers! logo please visit nzwine.com/members/
for Advertising and Promotion of Alcohol defines “light” (or “lite”) as advocacy and click into ‘Social Responsibility’.
containing a maximum of 2.5% alcohol by volume.
Statements about alcohol levels such as “low alcohol”, “lower in
alcohol”, “reduced alcohol” or “lighter in alcohol” do not count as
“nutrition content claims" so are not controlled by the restrictions
Ice wine
described in the section and flowchart above. However, producers
may voluntarily choose to follow a similar approach by ensuring New Zealand is a signatory to the World Wine Trade Group Agreement
that they include the identity of the reference product and the on Requirements for Labelling, which contains provisions regarding
difference between the alcohol content in the claimed wine and the use of the term “Ice Wine” / “Icewine”.
the reference wine. The Labelling Agreement defines “Ice Wine” / “Icewine” as a product
made from grapes that have been naturally frozen on the vine. Once
Low/Lower Alcohol Claims the agreement is fully implemented, only wines that comply with this
definition will be permitted for export to USA, Australia, Canada, Chile
Y and Argentina. However, wines that do not comply with this definition
Have you claimed Must beBatch consistency The EAN-13 barcode (encoding a 13 digit GTIN) is the barcode
Good winemaking practice suggests that where a wine has been used in New Zealand, Australia, Asia and Europe and is generally
produced and bottled in a number of batches, those batches acceptable worldwide for all retail/consumer items (e.g. individual
should be consistent in terms of organoleptic characteristics and bottles of wine, cartons of wine to be sold by the case). However,
chemical profile (allowing for testing tolerances and the effects for historical reasons, the USA and Canada have used a 12-digit
of maturation). Where batches of wine are produced that are not GTIN encoded into a barcode called a UPC-A. Most retailers in North
representative of other wine sold under the same label in a single America after 1 January 2005 should accept EAN-13 barcodes, but
market, we recommend that these be distinguished through their some still require a UPC-A.
labelling. For example, early batches of wine for immediate release Some retailers and wholesalers require special barcodes on cases
could be labelled as “Early Release”, “First Release” or similar. and pallets of wine, either for automated scanning on conveyor belts
(an ITF-14 barcode encoding a 14-digit GTIN) or for traceability
WHAT ELSE YOU SHOULD KNOW purposes (an EAN-128 barcode that can encode details such as
Cleanskins batch, processing date, Global Location Number of the vineyard etc).
Wines sold as “cleanskins” by the bottle or the carton, still need to It is vital that before printing your labels that you check that your
comply with labelling regulations when they are sold at retail or in barcode scans easily. A ‘pass’ on the international standard for
the on trade. barcode quality – a ‘verification test’ - is often a trade requirement.
For further information and assistance contact
If cleanskin wines are sold at wholesale, they must still bear the
GS1 New Zealand at www.gs1nz.org or 04-494 1050.
product name (e.g. “wine”, “Cabernet Sauvignon”, “Port”), lot
identification and name and address of the supplier on the bottle Wines over 15% alcohol
or carton. Further information on mandatory labelling requirements
There is no legal maximum alcohol limit for table wine or fortified
must be provided to the wholesale purchaser on request.
wine in New Zealand. However, fortified wine over 15% alcohol
Cartons may not be sold in a supermarket, but may be sold in other off-
licensed premises.
Outer packaging does not need to be labelled or marked if it is:
Note: Excise is payable at the higher fortified wine rate if a wine is
• for the purposes of transportation and distribution only; and over 14% alcohol and has been fortified with spirits. However, if a
• of a kind intended to be removed before the food is offered table (i.e. unfortified) wine is over 14% alcohol it does not qualify
for the higher excise rate. It is the addition of fortifying spirit,
for retail sale; and
rather than the alcohol level, that makes a wine qualify for the
• customarily not taken away by the purchaser of the food higher excise rate.
However, if you intend to sell wine at retail by the case, then:
• each bottle should be properly labelled; and
• the outer carton should bear the product name (e.g. wine,
Chardonnay, etc) together with either the number of the
bottles contained in the outer package and the quantity of
each of those bottles (e.g. 12 x 750ml) or the total quantity
(e.g. 9 litres)
If you are selling unlabelled cleanskins at wholesale, you need to
mark the carton as set out above.
Note: These guidelines apply to New Zealand only. Different
countries’ retailers or importers (e.g. Canada’s LCBO Product
Packaging Standards) may have their own requirements.
Barcodes
There is no legal requirement to include a barcode on your label.
Barcodes are usually required by retailers.
A barcode is essentially a method for encoding in machine-readable
format a unique number for a product which is called a Global Trade
Item Number (GTIN).
10 © New Zealand Winegrowers I nzwine.comAUSTRALIA
AUSTRALIAN LABELLING LAWS
The Australia New Zealand Food Standards Code (Code) applies Please note that it is illegal to use protected names [other than
to both Australia and New Zealand. New Zealand wines labelled in in compliance with the prescribed conditions] in the description
accordance with the Code will comply for the Australian market as and presentation of wine in any context whatsoever, even in an
otherwise true statement in textual form on a back label (eg.
regards mandatory information. The effect of the Trans Tasman
‘this wine is made from a typical Bordeaux blend of grapes’, or
Mutual Recognition Arrangement (TTMRA) and the Australia New
‘Marsanne is a native variety of the Rhone Valley’, or ‘my family
Zealand Closer Economic Relations Trade Agreement (ANZCERTA) have grown grapes in Chianti for generations’, or ‘this wine is
also means that, in general, a wine that can be legally sold in New from vineyards near the famous Barossa Valley’ or ‘this wine
Zealand can also be sold in Australia. is equal to a top Hunter Semillon’). Protected Names are only
protected when describing a wine, but it is difficult to say that
MANDATORY INFORMATION anything on a wine label is not describing that wine. Note that
A label designed in compliance with New Zealand labelling laws can country names are also protected. To clarify the boundaries for
also be used for wines exported to Australia. use of Protected Names, you could, in say promotional material,
use Protected Names to describe family history, or discuss
OPTIONAL INFORMATION generally the wine styles you make, or comparing your climate
conditions with European regions etc but whenever you are
Again, the situation is generally the same as applies in New Zealand,
describing a particular wine then Protected Names cannot be
although care is needed in relation to geographical indications. used in any context.
Protected Geographical Indications (GI)
The Australian provisions on the protection of certain European and Note that this protection can have unintended consequences. AGWA
Australian geographical indications are excluded from the mutual recently issued guidance that the term “orange wine” should not be
recognition arrangements between Australia and New Zealand. This used as it conflicts with the Australian GI “Orange”.
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 26th EDITION I March 2017 11EUROPEAN UNION (EU)
EU LABELLING LAWS
All Member States of the European Union share the same general In every case, wines must comply with the definition that applies to
labelling laws. In some cases, different authorities in various each category (see Annex 4 for more information on sparkling wine).
countries will have different interpretations of those laws, or The category of grapevine product must appear in the same
additional national requirements. field of vision as the country of origin, the net contents, and the
The main laws are Regulation 1308 of 2013 (the core EU alcohol declaration. All mandatory information required to appear
agriculture law) and Regulation 607 of 2009 (the wine labelling in the single field of vision must be at least 1.2 mm in height.
law). There are a number of other laws that touch on aspects of
Sweet and high alcohol wines
labelling, such as fair trading, allergen declarations and organics.
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 20% 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.
• no sweetening or sugar adjustment
MANDATORY INFORMATION Outside those parameters, the wine will need to come within one
Presentation and placement of the following special categories: “wine of overripe grapes” or
All compulsory statements must be easily readable, in indelible “wine of raisined grapes” and be labelled as such. The definitions
characters large enough to stand out against the ground on which are as follows:
they are printed and clearly distinguishable from all other content of
Wine from overripe grapes:
the labelling.
• is produced without enrichment
The following information must appear in a single field of
vision clearly distinguishable from all other content and printed • has a natural alcoholic strength of more than 15% vol
horizontally: • has a total alcoholic strength of no less than 15 % vol. and an
• category of grapevine product (i.e. product name) actual alcoholic strength of not less than 12% vol
• country of origin (what the EU calls “indication of • no maximum actual alcohol % vol.
provenance”)
Wine from raisined grapes:
• net contents; and
• is produced without enrichment, from grapes left in the sun or
• alcohol declaration shade for partial dehydration
All mandatory information required to appear in the single field of • has a natural alcoholic strength of at least 16% vol (or 272
vision must be at least 1.2 mm in height, based on the height of a grams sugar / litre)
lowercase letter ‘x’ of the font you are using.
• has a total alcoholic strength of at least 16 % vol. and an
If a geographic indication is used, this must also appear in the same actual alcoholic strength of at least 9% vol
field of vision.
• no maximum actual alcohol %
You can repeat mandatory information in other places on the label.
We recommend that all wines with more than 15% total alcohol
Product name use one of these designations on the label to avoid problems in
the market.
All imported wine labels must bear the “category of grapevine
product” (i.e. product name): Country of origin
• for still, unfortified wines of less than 15% total alcohol, the All imported wines must bear an “indication of provenance” on the
category of grapevine product will simply be “wine” label. For New Zealand wine, the indication of provenance will be
• fortified wines must use the designation “liqueur wine” and “New Zealand”.
wines over 15% total alcohol must use the designation “wine The category of grapevine product can appear together with the
of overripe grapes” or ”wine of raisined grapes” indication of provenance as “New Zealand Wine” (recommended) or
• sparkling wines may use the categories: sparkling wine, “Wine of New Zealand”. Alternatively it can appear as “Product of
quality sparkling wine, quality aromatic sparkling wine, New Zealand”, “Produced in New Zealand” or equivalent expressions.
aerated sparkling wine, semi-sparkling wine or aerated
semi-sparkling wine
12 © New Zealand Winegrowers I nzwine.comThe indication of provenance must appear in the same field of language of the market in which the wine is sold. American spellings
vision as the category of grapevine product, the net contents, and (“sulfites”, “sulphur”) are permitted. The declaration can appear on
the alcohol declaration. All mandatory information required to appear any label. The sulphite declaration must be at least 1.2 mm in height.
in the single field of vision must be at least 1.2 mm in height. Many EU Member States require that the sulphite declaration is in
the national language or languages. This will present difficulties for
Alcohol by volume
wineries exporting to multiple EU markets, as it may be necessary
All imported wine labels must bear a statement of alcoholic content. to have different sulphite declarations for each market. A list of the
This must be expressed as x% vol. in whole or half units (e.g. 12% relevant languages is attached at Annex 3B.
vol., 12.5% vol.) It may be preceded by the words “actual alcoholic
The following pictogram may be used on the label in addition to the
strength”, “actual alcohol” or “alc”. The minimum print size is 3mm for
written form of the sulphite declaration. However, it is not compulsory.
a 750ml bottle. The tolerance for the alcohol statement is +/- 0.5%vol.
The alcohol statement must appear in the same field of vision as the
category of grapevine product, the net contents, and the country
of origin. All mandatory information required to appear in the single
field of vision must be at least 1.2 mm in height. eg. x% vol, actual
alcoholic strength x% vol., actual alcohol x% vol., alc x% vol.
Net contents
All imported wine labels must bear the net contents. This must be
expressed in litres, centilitres or millilitres, and must be at least Allergen declaration
4mm in height when appearing on a 750ml bottle.
Labels for wines exported to the EU must include an allergen
The net contents must appear in the same field of vision as the
declaration if:
category of grapevine product, the country of origin, and the
alcohol declaration. All mandatory information required to appear in • they are produced from grapes grown in the 2012 vintage or
the single field of vision must be at least 1.2 mm in height. subsequent vintages; and
• they contain traces of milk or egg products (see below for
Importer further information); and
All imported wine labels must bear the name of the importer, • they are labelled in New Zealand on or after 1 July 2012 (or in
together with the local administrative area and Member State in the case of bulk wine, they have entered the EU market after
which their Head Office is located. These details must be preceded that date)
by the words “importer” or “imported by”. ‘”Importer” is defined As noted above, it is only necessary to label wines if they contain
as: a natural or legal person or group of such persons established traces of milk or egg products. The EU has specified that methods
within the Community assuming responsibility for bringing into of detection recommended by the International Vine and Wine
circulation non-Community goods. If the same wine enters the EU Organisation (OIV) may be used. This requires an ELISA test kit that
market (i.e. is released from bond) in more than one country, the can test to the limit of detection of 0.25 mg/L. You should contact
importer in each country may need to be included on the label. your laboratory for further information.
The importer details may appear on any label. The importer details The declaration can appear on any label. The form of the
must be at least 1.2 mm in height. declaration is “contains milk” or “contains egg” in the approved
However, the UK Food Standards Agency has advised that for wine language of the market in which the wine is sold. If multiple
sold in the UK, only the UK importer address should appear on the allergens are present (including sulphites) you do not need to
label. Other EU Member states have not imposed this restriction. repeat the word “contains”. Lists of the relevant languages,
permitted wording and translations are attached at Annex 3.
Sulphite declaration
The allergen declaration must be least 1.2 mm in height.
All imported wines must bear a sulphite declaration if they contain
You can also choose to use one of the official pictograms in Annex
more than 10 mg/l of sulphur dioxide. The form of the declaration
3D. This is optional but if you choose to use them they must still
is "contains sulphites" or "contains sulphur dioxide" in the approved
NEW ZEALAND WINEGROWERS’ LABELLING GUIDE 26th EDITION I March 2017 13be accompanied with the “contains milk/egg” statements. Allergen geographical unit/area (e.g. Bendigo); and
declarations for fish products are not required in the EU. • the remaining 15% comes from the geographical indication
(e.g. Central Otago).
Lot identification
All imported wine labels must bear a lot number on a label or on the Variety
bottle. This should appear as “L” followed by an alphanumeric code A grape variety may be used on the label of a wine exported to
(e.g. “L1234” or “L123AB”). the EU. Only varieties that are on the list of approved varieties
submitted to the OIV may be used. All vinifera grape varieties grown
Health advisory (France only)
in New Zealand that we are aware of are currently on the list.
French law requires all wine to bear the following health message However, if you are developing a new variety, we recommend that
and/or pictogram: you check with us whether the variety is listed or not.
« La consommation de boissons alcoolisées pendant la grossesse,
New rules seek to prevent or limit New Zealand producers using
même en faible quantité, peut avoir des conséquences graves sur
la santé de l’enfant. » some Italian grape variety names including: Barbera, Freisa,
Montepulciano, Nebbiolo, Primitivo, Sangiovese, Verdicchio and
Vernaccia. Whether of not these restrictions are legitimate, to avoid
challenge in market, appropriate synonyms may be used.
The minimum content for a single grape variety is 85%. Two or
more varieties may be used on a label, however the wine must be
The text of the message means: “The consumption of alcoholic derived 100% from the stated varieties and they must be presented
beverages during pregnancy, even in small quantities, can have in descending order of proportion in letters of the same height.
serious effects on the health of the child.” Where a single grape variety appears in conjunction with a vintage,
The health message should be written in contrasting type, so as to then the 85% rule applies concurrently (e.g. if a wine label says
be visible, readable, clearly comprehensible, and indelible. It must 2004 Cabernet Sauvignon, then it must contain at least 85% 2004
not be obscured or interrupted by other indications or images. It Cabernet Sauvignon).
does not need to be in any particular colour or size. Note that the UK Wine Standards has expressed the view that the
The health message must appear in the same field of vision as the grape variety name must be clearly distinguishable from other
alcohol declaration. This has implications for how labels are designed information, meaning that vintage dates or brand names may not be
for multiple markets that include France. If you wish to avoid having permitted on the same line close to the variety name.
to put the health message on your front label, you will need to place
Vintage
all of your “single field of vision” information (which includes the
alcohol declaration) on the back label. You may still repeat the “single A vintage date may be used on the label of a wine that bears a
field of vision” information on the front label if desired. geographical indication. The minimum content for a vintage date is
The UK has confirmed that this warning/pictogram is acceptable in 85%. Where a single grape variety appears in conjunction with a
their market, but we have not received such confirmation from other vintage, then the 85% rule applies concurrently (e.g. if a wine label
markets. We have received advice that the USTTB has indicated that says 2004 Cabernet Sauvignon, then it must contain at least 85%
the French warning/pictogram is not acceptable in the USA. 2004 Cabernet Sauvignon).
Production methods
OPTIONAL INFORMATION
References to production methods are generally permitted.
Note that NZ rules (including, for example, the 85% rule) represent However, certain references, including “bottle fermented”,
a baseline that must be met in addition to EU standards. references to oak aging and “rosé” are subject to special rules.
Geographical indication
Bottle fermented/ traditional method
The geographical indications permitted for use in the EU are set
out in Annex 2. To use a geographic indication, the wine must be at Specific rules apply to the use of the term “bottle fermented”,
least 85% from the stated region. No more than one geographical including a requirement that the wine undergoes secondary
indication may be used on a label. However, the names of smaller fermentation in a bottle of at least 90 days. More stringent rules
or larger geographical units and geographical area references may apply to wines described as “traditional method”, “méthode
also be used (e.g. Bannockburn, Central Otago) provided that: traditionnelle”, “classical method”, “crémant” etc. See Annex 4 to
this guide for more information.
• at least 85% of the wine is sourced from the specified
14 © New Zealand Winegrowers I nzwine.comTraditional terms Rosé
“Traditional terms” are terms that the EU considers should be used Under EU rules, red wine may not be added to white wine to
exclusively with EU protected geographical indications. Exporters produce a “rosé”. However, OIV rules (which can be followed by
should be aware that a number of “traditional terms” are now NZ producers as an alternative to EU rules) permit blending of
protected in the EU in their specified language. Key “traditional different wines without any limitation on production of rosé wine.
terms” of relevance to New Zealand exporters (protected in the Both EU and OIV rules permit blending of white wine into a red wine
bracketed languages) include: to produce a red wine (e.g. Syrah/Viognier).
AUSLESE (GER); SPATLESE (GER)
Our interpretation is that NZ producers can continue to produce
CREAM (EN) VILLAGES (FR)
wines blended from red and white varieties. However, it is not clear
PREMIUM (CZ) CLASSIC (GER, EN)
whether these wines can be called “rosé”.
VENDAGES TARDIVES (FR) NOBLE (SP)
Rosé wines produced from red grapes (e.g. by the saignée method)
CHATEAU (FR) SUPERIOR (POR, SP)
can be labelled “Rosé”. Addition of red wine to white wine for the
DOMAINE (FR) VINTAGE (EN)
production of sparkling rosé wine is permitted.
RESERVE (GER) CLARET (FR)
TAWNY (EN) RUBY (EN) Sweetness levels
CLOS (FR) SUR LIE (FR)
Sparkling wines must bear an indication of sugar content (e.g. brut,
FINE (IT)
sec etc). See Annex 4 to this guide for more information. For other
Note that Ruby, Tawny and Vintage are only protected in
wines, an indication of sweetness is optional but if it is used the
relation to fortified wines.
wine must fall within the appropriate sweetness range as below.
Traditional terms are only protected in the language and for the
categories of grapevine products specified in the regulation. This
Dry, sec, etc. If its sugar content does not
is generally taken to mean that, for example, “Reserve” is only
exceed:
protected when used on a wine label in the German language.
4 grams per litre, or
However, if the use of such a term on an NZ wine label in the EU
9 grams per litre, provided
could be confused with its use as an EU traditional term then that that the total acidity
could also potentially create a problem. Enforcement of the rules is expressed as grams of
at the discretion of the Member States in which potentially infringing tartaric acid per litre is not
product is sold. 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 Medium dry, demi-sec etc If its sugar content exceeds
on the label of a New Zealand wine in the EU could potentially be the maximum set out above
in breach of EU regulations. but does not exceed:
12 grams per litre, or
Oak aging 18 grams per litre, provided
that the total acidity
The following terms are currently the only terms permitted to describe
expressed as grams of
wine that has been fermented, matured or aged in a wood container. 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
[indicate the type of [indicate the type of [indicate the type of
moelleux etc. than the maximum set out
wood] wood] wood]
above but not more than 45
CASK FERMENTED CASK MATURED CASK AGED grams per litre.
These terms may only be used in relation to a wine that bears Sweet, doux, dolce etc. If its sugar content is of at
a geographical indication. Reference to wood containers is not least 45 grams per litre.
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 26th EDITION I March 2017 15You can also read
