Additional labelling terms

This section provides information on additional labelling terms and optional label claims that apply to wine labels in Australia. Most of these terms are optional claims, however, if you choose to use a term on your label it must comply with any definitions outlined below.

Optional information

Amber/Skin contact wine

Orange became a registered geographical indication on 31 October 1997, and as such, is afforded the same level of protection as all other registered GIs. Therefore, the term ‘orange wine’ cannot be used to describe skin contact white wines, unless the fruit has been sourced from the GI of Orange.

An exemption from the false and misleading description and presentation provisions exists to allow for the use of a ‘common English word’, which orange would qualify for. However, it must be used in good faith, and in such a way that is not likely to mislead as to the origin of the wine. To make it abundantly clear to the consumer that orange is being used to describe colour there must be sufficient context to support the claim, i.e. ‘Wine with an orange hue’ or ‘orange in colour’. Alternatively, ‘amber’ is an acceptable replacement for orange when presenting or describing skin contact white wines, or wines that are amber in colour.

Apera and Topaque

‘Apera’ and ‘Topaque’ are registered certification Trade Marks of Wine Australia which may only be used by approved users. The term Apera was developed by the wine sector to replace Sherry, with this term protected since 1 September 2011. The term Topaque replaced ‘Tokay’, which was protected since 1 September 2020. Use of the terms is subject to conditions including, but not limited to the following:

Apera

  • the term may only be used to describe Australian fortified wines
  • the fortified wine must comply with the taste, aroma and characteristics of an Apera wine referred to in the Australian Wine Industry Fortified Wine Code of Practice
  • the term must appear on the label in the same field of vision as the producer’s distinguishing trade mark
  • the term must always appear with a font size equal to or less than 50 per cent of the size of the distinguishing trade mark.

Topaque

  • the term may only be used for Australian fortified wines

If you wish to use either term on your label, contact Wine Australia. A copy of the current licence agreements can be found for Apera here and for Topaque here.

Bar codes

Bar codes are not required by law or regulated as to size or placement. They are, however, increasingly required by wholesalers and retailers in Australia and overseas. The 13-digit EAN (European Article Number) is the most commonly used in Australia and Europe and the only one now accepted in Canada. The USA accepts both EAN and the 12-digit UPC (Universal Product Code). The EAN system can read UPC, but the reverse does not apply.

For further information regarding either system contact GS1 Australia.

Brand names

Brand names (or any other name) should not mislead as to the origin, age or identity of the wine. If a brand name (or business name) contains a registered geographical indication it can only be used on the label when the wine has been sourced from the relevant GI.

Regulation 32 of the Wine Australia Regulations allows for the co-existence of Australian geographical indications and trade marks which were registered by IP Australia prior to the registration of the geographical indication. See label examples at description and presentation.

Cabernets

The term ‘Cabernets’ was adopted by the Australian wine industry to replace the term ‘Bordeaux’ which was listed on the Register as a protected geographical indication in 1994. Not to be confused with the varietal claim ‘Cabernet’, which is a synonym for Cabernet Sauvignon, the term ‘Cabernets’ may be used in the description and presentation of a wine in place of a varietal claim to indicate one of two types of blends:

  • a blend comprising at least 85% Cabernet Sauvignon, Cabernet Franc and/or Ruby Cabernet
  • a blend comprising at least 85% of traditional ‘Bordeaux’ varietals (Cabernet Sauvignon, Cabernet Franc, Merlot, Malbec and/or Petit Verdot) provided that at least one of Cabernet Sauvignon or Cabernet Franc contribute to the blend. 

The context in which the term ‘Cabernets’ is being claimed must be clearly indicated on the label.

Carbon neutral claims

Carbon neutral claims are used to convey a message about the volume of carbon emissions associated with a particular thing, most often a product or an organisation. If a wine or a winery claims to be ‘carbon neutral’, then the net emissions associated with that wine or winery must be zero. Carbon neutral claims must comply with the Australian Consumer Law. This means that they must not be false, misleading or deceptive. Care should be taken when using broad terms that are capable of multiple meanings – for example: ‘green’, ‘carbon friendly’, ‘carbon compensated’ and ‘environmentally safe’.

Wine Australia has developed a Carbon Neutral FAQs document which includes details on the Climate Active Carbon Neutral Standards administered by the Department of Environment and Energy and links to the AANA Environmental Claims Code. The FAQs can be viewed here.

Carton labelling

The National Trade Measurement Regulations requires that if a pre-packaged product is packed or sold, the package containing the product must be marked with the name and address of the person who packed the product or on whose behalf it was packed. The carton must indicate either the total volume of the inner packages or the number of packages and the volume of each (e.g. 12 x 750 mL).

If products are offered for sale to consumers in the carton as a consumer unit (e.g. a three-bottle presentation pack) the Food Standards Code requires that all mandatory information for a wine label be reproduced (or the information be visible on the inner packages) on the outer carton.

Cleanskins (unlabelled wine)

It is not legal to sell or export wine without all mandatory items appearing on the packaging. Unlabelled bottles cannot be sold at retail to the public, but unbroken cartons of bottles can be sold if the mandatory information appears on the carton in an acceptable form. However, mandatory warning declarations including allergens must still appear on every bottle.

Dates on labels

Care should be taken when using historical dates or additional numeric references in the description and presentation of a wine to avoid misleading as to the vintage of the wine. Other years may be referred to on wine labels, for example, to indicate when the winery was established, when a vineyard was planted, or when the winemaker joined the winery. When such references are made, it’s important to make sure that they won’t be interpreted as vintage claims.

To ensure references to a year that isn’t a vintage year is permissible, you should:

  1. give context to the non-vintage year (for example, use words like ‘planted in’, ‘established in’ or ‘produced since’)
  2. ensure the actual vintage claim is clearly stated
  3. ensure the actual vintage claim appears in the same field of vision as the reference to the other year, and
  4. ensure the actual vintage claim is more prominent than the reference to the other year.

Further information on using dates on labels can be seen here.

Display of awards and medals

The use of medals or awards in the description and presentation of wines is permitted, however care should be taken that they do not clash with any other labelling consideration (such as use of a protected term). The Australian wine sector has developed a Display of Awards Code of Practice which outlines how awards should be displayed. The Code is available from the AGW website.

Read more about the use of awards and medals here.

Fortified wine terms

A number of fortified wine terms are protected on the Register including cream, crusted/crusting, ruby, solera, tawny and vintage. It is an offence under the Act to include a registered term in the description and presentation of a wine that does not comply with the registered conditions of use applicable to that term. Refer to the Australian Wine Industry Fortified Wine Code of Practice for further information. The protected terms and their conditions of use can be seen on the Register in quality wine terms.

Icewine

Icewine is protected on the Register. The terms ‘icewine’, ‘ice wine’ or ‘ice-wine’ may only be used in the description and presentation of a wine when the wine is obtained exclusively from grapes naturally frozen on the vine. It is an offence under the Act to include a registered term in the description and presentation of a wine that does not comply with the registered conditions of use applicable to that term.

Maps on labels

Maps appearing on labels, brochures and advertising etc. form part of the description and presentation of the wine. If a geographical indication is named or referred to on a map, and the wine is not sourced from that GI, then it is a false or misleading label claim.

Moscato

Moscato is protected on the Register. The term ‘Moscato’ may only be used in the description and presentation of a wine when at least 85 per cent of the wine is obtained from a list of defined Muscat varieties (including Muscat a Petits Grains, Muscat of Alexandria, Muscat Gordo, Muscat Hamburg, Gewurztraminer etc). Refer to the Register for the full list of varieties. It is an offence under the Act to include a registered term in the description and presentation of a wine that does not comply with the registered conditions of use applicable to that term.

Read more about use of Moscato here.

Organic and biodynamic wine

Organic products intended for the Australian market are not required to be certified in order to be labelled ‘organic’. There is a voluntary standard for growers and manufacturers wishing to label products as ‘organic’ and ‘biodynamic’ for sale within Australia (AS 6000–2015). As it is a voluntary standard, businesses do not necessarily have to meet the requirements of this standard in order to label and sell their products as ‘organic’ or ‘biodynamic’ within Australia.

While organic certification is not legally required for a product supplied in Australia to be described as organic, businesses must be able to substantiate any such claims. Many organic businesses choose to be certified by an organic certification body to underpin truth in labelling requirements and promote consumer confidence. Certification for organic claims can be made by any of the many private organisations that perform this function.

Misleading, false or deceptive organic claims are prohibited under the Australian Consumer Law. The ACCC provides useful guidance on environmental and organic claims made in the domestic market.

For export, organic and biodynamic goods must comply with the Export Control Act 2020 and Export Control (Organic Goods) Rules 2021. Further information is outlined in export documents.

For export, organic certification is mandatory. Any mention of ‘organic’ or ‘biodynamic’ (or indication of similar meaning) in a wine’s description and presentation is considered an organic claim. Wines with organic claims require organic certification for export approval, and exporting wines presented as organic without certification is an offence under the Organic Goods Rules and can attract significant penalties. Further information can be found here.

Pinots

The term ‘Pinots’ may be used to describe a blend of two or more Pinot varieties including Pinot Noir, Pinot Meunier, Pinot Blanc and Pinot Gris, when these varieties comprise at least 85% of the blend.

Sparkling wine terms

Sparkling

The Food Standards Code defines a sparkling wine as a wine which has become surcharged with carbon dioxide as a result of complete or partial fermentation of contained sugars. Accordingly, wines which are carbonated by means of the addition of carbon dioxide to achieve effervescence should not be labelled as ‘sparkling’.

Methode champenoise

Methode champenoise is protected on the Register. The term ‘methode champenoise’ may only be used in the description and presentation of wines originating in the place indicated by the geographical indication ‘Champagne’. It is an offence under the Act to include a registered term in the description and presentation of a wine that does not comply with the registered conditions of use applicable to that term.

Traditional method

Traditional method is not a regulated term but is understood to indicate a sparkling wine made in the methode champenoise. ‘Traditional method’ may be used as an alternative descriptor on Australian sparkling wines.

Methode traditionelle

The term methode traditionelle is not a protected term and may be used as an alternative descriptor to ‘methode champenoise’ on Australian sparkling wines.

Pét-nat 

Pét-nat, or Pétillant Naturel, is a term commonly used to describe a type of sparkling wine that is made using lower intervention and natural fermentation processes. Pét-nats are bottled before the fermentation process is fully complete, resulting in carbon dioxide being formed from the natural sugars in the wine. The resulting wine is often cloudy in appearance. The term is not regulated but in order to satisfy the requirements of the Australian Consumer Law you should ensure wines labelled with this term are representative of the type of products that consumers would expect.

Vegetarian and vegan claims

Wine Australia does not regulate the use of ‘vegetarian’ or ‘vegan’ claims in relation to wine labelling.

‘Vegan’ is not defined, however, most consumers would understand vegan produce as not being made from, or perhaps not even coming into contact with any animal product, animal by-product or derivative of animal product such as gelatin, milk, egg or fish based fining agents used in the manufacture of wine. Other animal products that may be used in manufacturing wine include beeswax to seal bottles and agglomerated corks which use milk-based glues. The Australian Consumer Law prohibits businesses making ‘vegan’ or ‘vegetarian’ statements that are incorrect or likely to create a false impression.

The ACCC views label references to vegan as food type assurance claims. ‘Food-type assurance claims’ means claims referring to specific systems or processes that have been put in place to provide assurance to specific consumer groups or tastes. Claims that give such assurances must have a factual basis. For example, claims may be substantiated through well-documented certification processes and certification performed by authorised persons. Alternatively, you should be able to show reliable documentation to support your claim.

There are a number of vegan and vegetarian societies that have registered certification trade marks that you can apply for and pay to use.

Imported wine

Imported wine, other than wine from New Zealand,[1] must comply with the Imported Food Control Act 1992 which specifies that imported food comply with the Australia New Zealand Food Standards Code.

The labelling requirements set out in Part 1.2 and Part 2.7 of the Food Standards Code applies to imported wines. Imported wine must also comply with the production limits set out in Part 1.3 and Part 1.4 of the Food Standards Code and the related schedules, particularly Schedules 15, 16, 18, 19 and 20. The wine production requirements set out in Standard 4.5.1 apply only to Australian wines.

If an imported wine refers to a foreign country geographical indication or foreign place name at least 85 per cent of the wine must have been obtained from grapes grown in the country, region or locality indicated by the GI. If the wine is made from grapes grown in more than one country, the description and presentation of the wine must identify the proportion of the wine that originated in each country.

The false and misleading offence provisions of the Wine Australia Act also apply to imported wine if that wine has a description and presentation that includes a registered geographical indication or a registered translation of the indication and the wine did not originate in the country, region or locality indicated, or if the wine includes a registered traditional expression or a registered additional term and the wine does not comply with any registered conditions of use.

 

 

[1] New Zealand wine enters Australia under the Trans Tasman Mutual Recognition Agreement and the Australia New Zealand Closer Economic Relations Trade Agreement. Wine legally sold in New Zealand can be sold in Australia.


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This content is restricted to wine exporters and levy-payers. Some reports are available for purchase to non-levy payers/exporters.