The Label Integrity Program (LIP) is legislated under Part VIA of the Act.

The object of the LIP is to help to ensure the truth, and the reputation for truthfulness, of statements made on wine labels, or made for commercial purposes, about the vintage, variety or the geographical indication (GI) of wine manufactured in Australia.

The LIP imposes obligations on every party in the supply chain to make and keep records verifying vintage, variety and GI label claims made in relation to wine goods. The LIP does not prescribe how records are to be kept, only the information that must be recorded. This gives wine manufacturers flexibility in choosing a system that best suits their needs.

Who needs to keep records?

The LIP applies to:

• wine grape growers
• manufacturers of wine goods, including wineries, packagers and processing facilities
• persons who supply or receive wine goods (including a person who sells the wine goods by wholesale or retail or export)
• agents who take possession of wine goods.

The LIP applies to wine goods which includes grapes, wine, and grape extract used or intended to be used in manufacturing wine.

What records need to be kept

To verify label claims, everyone in the wine supply chain must keep an auditable trail of documents indicating the vintage, grape variety and geographical indication of wine and wine goods that they grow, manufacture, supply or receive (regardless of whether they are acting as an agent).

This effectively involves recording ‘one step forward’ and ‘one step back’. Records must be maintained in a form that allows a readily auditable trail to be established.

LIP records must be kept for seven years.

Supplying wine goods

When you’re supplying wine goods to another party (such as a grape grower supplying grapes to a winery, or a winery sending wine goods to another winery or a packaging facility), you need to provide an accompanying written record within three days of supply which includes at a minimum:

• the date you’re supplying the wine goods
• the quantity of wine goods you’re supplying
• the vintage, variety and prescribed GI of the wine goods you’re supplying.

Receiving wine goods

When you’re receiving wine goods (such as a packaging facility receiving wine from a winery, or winery receiving grapes during vintage) your own record must be made within three days of receiving the goods and must identify:

• who made the record
• the date you received the wine goods
• the type of wine goods and quantity of wine goods you received
• the vintage, variety and prescribed GI of the wine goods you received
• the identity of who you received the wine goods from (the individual or organisation’s name and address). 

Read more about harvest record keeping and grape intake here.

Processing or modifying wine goods

Regardless of where you fit into the wine supply chain, if you process, move, or modify wine goods, you are required to make a written record within three days outlining:

• details of the steps or action taken and the date it occurred 
• details of the vessels (e.g. tanks or barrels) that were involved in the processing step or movement (i.e. all vessels must be individually identifiable) 
• any changes to volume or quantity that occurred, including both gains and losses (including increases as a result of water being added to high sugar juice or must prior to fermentation) 
• any changes to the composition of the product (vintage, variety or prescribed GI) that resulted through processing activities (such as blending or barrel topping).

What are the penalties?

There are offences under the LIP for:

• failing to keep sufficient records
• making a false record, and
• failing to verify a vintage, variety or GI claim with sufficient records.

A maximum penalty of two years’ jail, or a fine of 120 penalty units instead of, or additional to imprisonment, applies for each offence.

Failing to comply with the LIP could also result in export licence cancellation or suspension, or your products being withdrawn from the market. Wine Australia can prevent the export and sale of grape products if vintage, variety or GI claims cannot be substantiated by records kept under the LIP.

See Wine Australia's LIP templates and guides for further assistance.