The LIP requires records to be made within three months after the happening of an event, circumstance or state of affairs that needs to be recorded (see below). They must be kept for seven years after the record is made.
To allow flexibility, the Act does not prescribe how records are to be made. A cheque butt may be sufficient record of a grape purchase, for example, provided the necessary information is recorded).
A diary system or computer system is most commonly used. If using a computer system, it is important to ensure:
You may at any time be selected for audit by an AWBC LIP Inspector. The audit may be a cold-call or, an arranged visit, or, may be a desk audit where copies of specific records are requested for audit at the AWBC offices.
An audit will usually require an audit trail to go backwards from the last stage of production of a selected product (e.g. sale, bottling, bulk storage etc.) by means of cross reference of volume, location (e.g. tank number) and label claim details right back to the receipt of grapes, or other wine goods, at the winery.
A blended label claim wine, which has been sold, would need to have cross referenced records from point of sale back through stocks, bottling, blending records, manufacturing records of each variety, crush records and grape receival records to verify the integrity of the product.
Records to be kept by wine manufacturers
Receipt of wine goods (AWBC Act, Section 39F)
- Date of receipt, quantity, vintage, variety, geographical indication, identity of supplier to be recorded
- All grape and wine goods receipts to be recorded, even if no label claim is to be made
- Records may be kept in any form (e.g. cheque butt, weighbridge docket, notebook, receipt book, computer etc)
- Where a winery does not have a weighbridge, an estimate of the volume (eg tonnes), or the method of calculating payment eg number of bins, buckets or litres produced, will suffice,
- Receipt of “wine goods” includes receipt of wine and all forms of grape extract, eg juice, must, concentrate
If no label claim is to be made on the finished product, there is no further requirement to make LIP records as required by the following Sections.
Manufacture of certain single wines (Section 39G)
This requirement applies if:
- a manufacturer intends to sell wine with a label claim, or
- the wine is manufactured on behalf of another person who intends to sell wine with a label claim, or
- the wine is intended at some time to be included in a blend with a label claim.
Records must:
- Include date of manufacture, quantity and, vintage, variety and geographical indication details.
- Provide an audit trail: i.e. cross reference from grape receipt (weigh-bridge) records, through crush records, all manufacturing stages, blending, bottling, stock records etc. to point of sale. Records should include: storage locations (tank number etc.), volume (litres), gains and losses (litres) at all stages of production and, such details of vintage, variety or geographical indication as are intended to be claimed.
Manufacture of certain blends (Section 39H)
This requirement applies if:
- a manufacturer intends to sell the blend with a label claim, or
- the blend is manufactured on behalf of another person who intends to sell the blend with a label claim.
Records must:
- Include date of manufacture, quantity and, vintage, variety and geographical indication details;
- Provide an audit trail: i.e. cross reference from grape receipt (weigh-bridge) records, through crush records, all manufacturing stages, blending, bottling, stock records etc. to point of sale. Records should include: storage locations (tank number etc.), volume (litres), gains and losses (litres), proportions of blend details (%), at all stages of production, and such details of vintage, variety or geographical indication as are intended to be claimed.
- Be cross referenced to the single wine records from which the blend is sourced
- Include the vintage, variety or geographical indication proportions (percentage) of the blend at each stage of production.
Sales of certain wine (Section 39J)
The following applies to all label-claim wine. See also direct sales below.
- Date of sale, quantity, label claim details (vintage, variety, geographical indication), identity of purchaser must be recorded.
- Except, where a wine manufacturer sells wine packaged for sale to consumers and, the package has a wine label showing the manufacturers name and address, the manufacturer is not required to make a record of the identity of the purchaser.
- A wine may not be said to be without a label claim if, on the sales, transport or any other documents, there is a reference to either vintage, variety or geographical indication.
Disposals of certain wine (Section 39K)
Where a wine manufacturer, who manufactures label claim wine for another person, disposes of the wine the following disposal records must be kept: Date of disposal, quantity, label claim details and identity of purchaser (subject to the same exception as in Sales of certain wine and Direct sales);
Normally the wine would be transferred back to its owner but, if it is sold in direct sales by the manufacturer, then the requirement to record the identity of the purchaser is exempted.
Direct sales (Section 39L)
Where a manufacturer sells label claim wine in direct sales, in a particular period not exceeding one year, the manufacturer may, instead of making and keeping a record of the date of sales and quantities (and identification of purchasers), make and keep a record of the period and of the total quantity of the wine sold in the period.
For the purposes of the LIP, this releases winemakers from the necessity to record details of individual direct sales. A record of total sales for each label claim product for a certain period (of no more than twelve months) is all that is required to be kept.
Transfers of certain wine (Section 39M)
Where a wine manufacturer transfers wine (including that manufactured for another person) from a winery of the manufacturer to another winery of the manufacturer, for blending, bottling etc., it is necessary to record:
- Date of transfer, quantity, the winery from which, and to which, the wine is transferred, and label claim details.
- This applies to all wine which has a label claim or is intended to be sold with a label claim by the manufacturer or another person.
Production of certain grape extract (Section 39N)
Where a wine manufacturer produces grape extract for use in manufacture at another winery of the manufacturer or, for sale or, on behalf of another person and, the product is intended to have a label claim, it is necessary to record:
- Date of production, quantity, label claim details (vintage, variety, geographical indication)
- All grape extract, which has, or is intended to have, a label claim, which is transferred between a manufacturer’s premises or transferred out of the manufacturer’s premises, must have the above details of manufacture recorded.
Sales of certain grape extract (Section 39P)
Where grape extract, with a label claim, is produced and sold by a wine manufacturer for use in manufacturing wine it is necessary to record:
- Date of sale, quantity, label claim details, identity of purchaser
- Sales of all label claim grape product must be recorded.
Disposal of certain grape extract (Section 39Q)
Where a wine manufacturer produces and disposes of label claim grape extract on behalf of another person it is necessary to record: Date of disposal, quantity, label claim details, identity of that person, and, identity of person to whom delivered (if another person).
Transfers of certain grape extract (Section 39R)
Where a wine manufacturer transfers label claim grape extract to another winery of the manufacturer or, to a winery of another person for use in manufacturing wine, it is necessary to record: Date of transfer, quantity, winery transferred from, winery transferred to, label claim details.
Characteristics to be recorded (Section 39W)
If there is to be a vintage claim - the vintage(s) of the wine or extract
If there is to be a varietal claim - the variety(s) of the wine or extract
If there is to be a geographical indication claim - the geographical indication(s) {regions of origin}of the wine or extract.
The record must show details of every step the wine manufacturer took in manufacturing the wine or extract, that changed or affected the vintage, variety or geographical indication, or:
in any case - the tank or other place or thing in which the wine or extract was stored; or
in any case - the volume of the wine or extract stored in any such tank, place or thing.
The details required above in relation to a wine or extract must be in a form that allows an audit trail containing its history of the wine's manufacture to be readily traced from the record. It must be possible for the details of the steps taken and the results of the steps to be readily checked for discrepancies by following the sequence of the steps recorded.