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When is your wine not a wine (and why does it matter)?

Exporter News | February 2020
27 Feb 2020
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If it looks like a duck, swims like a duck and quacks like a duck, then it probably is a duck. But you can’t always apply the duck test to wine.

Humour aside, truth in labelling is a serious matter. We occasionally receive export applications for products that aren’t technically wine but are still considered grape products for export purposes. To avoid headaches (and potential relabelling) at the point of export, it is critical to ensure your products comply with the relevant standards and are packaged correctly.

The Australia New Zealand Food Standards Code(the Code) defines wine as;

the product of the complete or partial fermentation of fresh grapes, or a mixture of that product and products solely derived from grapes.[1]

If you add anything that isn’t derived from grapes, or isn’t listed as a permitted additive or processing aid under Standard 4.5.1, your product isn’t a ‘wine’ in the context of the Code. Having an accurate ‘name of the food’ on your packaging is mandatory[2] and compliance with the Code is a condition of export approval, in addition to a requirement for sale of your product in Australia more generally.

So, if your product isn’t a wine, what is it? Well, it might be a ‘wine product’ which the Code defines as;

‘…a food containing no less than 700 mL/L of wine, which has been formulated, processed, modified or mixed with other foods such that it is not wine.’[3]

Some examples of wine products could be a white wine with added fruit or botanicals, a fortified wine with added chocolate, or a sparkling wine with edible gold leaf. However, you can’t apply a ‘one-name-fits-all’ designation and need to consider each product based on its composition. Labelling only as a ‘wine product’ mightn’t be sufficient in some cases. Where relevant, further information should be given, such as ‘wine product with added fruit flavour’ or ‘wine product with added natural colours’. In addition, exported wine products can’t display a geographical indication (GI) other than ‘Australia’, and as with all Australian grape products, there’s restrictions on the use of protected terms including European GIs and Traditional Expressions.

If you’ve got less than 700 mL/L (i.e. 70 per cent) of wine in your product, then it isn’t a wine product and might be considered an unstandardised beverage (to put it another way, the Code doesn’t have a standard that applies to it). For these beverages, the name or description you use must clearly indicate the true nature of the product – ‘call a spade, a spade’, as the saying goes.

It’s also important to consider that although something might be permitted overseas, it doesn’t mean it’s automatically permitted in Australia – and vice versa. Some food ingredients or production techniques aren’t permitted irrespective of whether you’re making a wine, wine product or other wine-based beverage. For example, use of Acacia-wood barrels is prohibited in Australia since it’s a prohibited plant under Schedule 23 of the Code[4]. Similarly, several overseas markets prohibit the use of certain additives or processing aids which are permitted in Australia, and we note this in our Export Market Guides where possible.

If you’re thinking about experimenting with making something a little different, or would like guidance on compliance with the Code and other wine legislation, get in touch.


[1] Australia New Zealand Food Standards Code Standard 4.5.1

[2] Australia New Zealand Food Standards Code Standard 1.2.2-2

[3] Australia New Zealand Food Standards Code Standard 2.7.4-2

[4] Robina pseudoacacia, also known as False acacia and Black locust

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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.