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‘Brexit’ update - July 2019

Exporter News | July 2019
Photo: Adobe Stock
09 Jul 2019
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In the January edition of Exporter News, we discussed potential labelling changes that would be needed for wine sent either to the United Kingdom (UK) and/or the remaining European Union (EU) members once the UK left the EU (which at that time was expected to happen on 29 March 2019). Since then, with the March deadline passed, a revised withdrawal date was set for 31 October 2019.

Nevertheless, we have used the intervening time to gain some additional clarity around labelling requirements that will follow the UK’s withdrawal.

The only significant labelling change concerns the obligation to include the details of the importer. We suggested, in January, that one way to comply post-Brexit would be to include details of both the person responsible for bringing the wine into the UK and the one responsible for bringing it into the remaining 27 EU States. Our discussions with UK authorities have confirmed that this would be an acceptable approach in that market.

Unfortunately, however, the European Commission do not have the same flexibility and only the name and address of the relevant EU importer can be displayed in the remaining 27 markets. Including the details of the UK importer would only be permitted if clearly separated from the word ‘importer’ or ‘imported by’ and does not mislead consumers over the entity responsible for bringing the wine into the EU.

We will continue to discuss this matter with the European Commission in the hope that their position may change prior to the UK’s withdrawal. In the interim, the safest option is to modify labels in order to comply with the position of the European Commission.

A further consideration is the impact of the UK’s withdrawal on the required import document, the ‘VI-1’ certificate.

The suite of analyses will be the same, post-Brexit, regardless of whether a shipment is bound for the UK or the EU.

The UK has, however, drafted a revised format for the document intended for use on shipments entering the UK once Brexit is complete. The changes are purely cosmetic and Wine Australia’s new export approval system (WALAS) has been designed to distinguish between the two documents.

Uncertainty remains, however, in the situation where wine is exported in bulk to the UK prior to packaging for subsequent shipment to the EU.

In these circumstances, the EU VI-1 form would need to be drawn up by UK authorities, not by Wine Australia. It is not yet certain they have the resources necessary to cope with what would appear to be an enormous number of transactions.

We will continue to keep you informed of developments as the Brexit deadline looms.

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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.