We have previously alerted exporters to new chemical analysis requirements in order to send wine to Thailand and Brazil.
Our earlier advice on these requirements can be found here. At the time of the previous advice (April 2019), these certificates were yet to be implemented but now both are in force and there have been some important developments.
The good news is that an indication of fusel oil and of ethyl acetate content is no longer expected on the Thai certificate. Furthermore, the limit on sulphur dioxide has been increased to 400 ppm (but this exceeds limits imposed by the Australia New Zealand Food Standards Code, so is of academic interest only)
On the other hand, a limit on ethyl carbamate content has been introduced.
The suite of analyses is listed below, with their associated limits.
Several of these analyses are not routinely conducted on wine in Australia so obtaining a certificate from an Australian laboratory may be difficult and expensive. There is, however, no need to seek certification from an Australian laboratory because your Thai importer can submit samples to a local laboratory. Our understanding is that the Bangkok laboratory will analyse samples within five days and there is no associated cost. We also believe that the analysis certificates produced this way are valid for three years. The certificates remain valid despite vintage changes during that time, provided the brand and grape varieties remain the same.
However, if your Thai customer demands a certificate from the source, and you want a satisfied customer, then the required analyses are:
- alcohol (tolerance of +/- 1.0% from label statement)
- sulphur dioxide (400 ppm)
- sorbic acid (200 ppm)
- methanol (420 ppm)
- acetaldehyde (160 ppm)
- benzoic acid (250 ppm)
- arsenic (0.1 ppm)
- lead (0.2 ppm)
- ferrocyanide (nil), and
- ethyl carbamate (200 ppb).
Note that benzoic acid is not a legal wine additive in Australia.
As with Thailand, the suite of analyses required to accompany shipments of wine to Brazil has changed from our previous advice. They are now understood to be limited to the following:
- total acid (meq/l pH 8.2)
- volatile acid (meq/l)
- total sulphates (expressed as potassium sulphate in g/l)
- sugar-free extract (g/l), and
- methanol (mg/l).
So, the good news is that chlorides, citric acid, artificial colour and ash are no longer listed as items that the Australian laboratory must perform prior to shipment. On the other hand, it seems these additional parameters will be tested by a laboratory in Brazil, along with duplication of the work performed by the laboratory in Australia.
There has also been confusion about what is meant by the Brazil certificate. In fact, there are three such certificates. The first is the analysis document discussed above. This used to be incorporated into the certificate of origin but is now separated from that certificate. Therefore, the format for the analysis certificate is no longer defined, but must include the six parameters listed above.
In addition to the analysis certificate, however, a certificate of origin is required. This format is defined and a template can be found here.
Finally, there is a third certificate, a typicity certificate, required in the event that a result from the analysis document exceeds Brazilian specifications. The most common circumstance under which this would be needed is if the alcohol content of the wine exceeds 14 per cent. A template can be found here.
Further information on Brazilian requirements can be found here. Page 745 is particularly important. It is in Portuguese but the table on that page is quite easy to read and lists the minimum and maximum limits for each parameter. The first column after those limits identifies those items that must be provided by the laboratory in the exporting country (‘S’ means yes and ‘N’ means no) and the second column identifies those items that are checked on arrival in Brazil.