Label Integrity Program
The object of the label integrity program is to help to ensure the truth, and the reputation for truthfulness, of statements made on wine labels, or made for commercial purposes in other ways, about the vintage, variety or Geographical Indication of wine manufactured in Australia.
Who does the Label Integrity Program apply to?
- Wine grape growers
- Manufacturers of wine goods
- Persons who supply or receive wine goods (including a person who sells the wine goods by wholesale or retail or export)
- Agents who take possession of wine goods
Winemakers are not required to make a label claim about the wine vintage, grape variety or Geographical Indication, but must keep an audit trail if they do. The LIP prescribes what events must be recorded, but not how records must be kept.
As a guide, the Australian Wine and Brandy Corporation provide LIP Statement templates and Recordkeeping templates which can be downloaded (see below).
The full regulations are included in the Australian Wine and Brandy Corporation Act 1980 (Part VIA, Sections 39A - 39ZL).
What does the LIP cover?
The LIP applies to “wine goods” which includes wine or grapes or grape extract used or intended to be used in manufacturing wine.
What is a Label Claim?
A label claim means a written claim made or implied about a wine goods’ vintage, variety or geographical indication on wine labels, records, commercial documents or in advertisements.
The AWBC has published a Guide to Labelling with Geographical Indications to assist wine manufacturers comply with the relevant requirements.
What must be recorded?
One step back:
- The date the wine goods are received
- The type, quantity, vintage, variety and GI of the wine goods received
- The identity of the supplier
One step forward:
- The date the wine goods are supplied
- The type, quantity, vintage, variety and GI of the wine goods supplied
- The identity of the customer
A Wine Goods Supply Statement must accompany the transfer of wine goods between wine grape growers, manufacturers of wine goods and persons who supply or receive wine goods. The format of this statement is not prescribed. A standard commercial invoice would satisfy the requirements provided it includes; date of supply, identity of supplier and customer, quantity of product and the vintage, variety, and GI.
What are the Penalties?
The Act provides for a penalty of 2 years imprisonment or a maximum fine of 120 penalty units instead of, or additional to imprisonment for failure to keep a record, keeping a false or misleading record, or for making a label claim not supported by records or for failing to provide a copy of the record when supplying wine goods.