What do Ballarat, Berri, Bellarine, Ballandean and Birdwood have in common? Read on and it’ll become clear.
Winemakers in Australia aren’t bound by regional rules when it comes to blending, meaning that we have the freedom to combine vintages, varieties and regions to create a blended wine. However, there are strict rules around the labelling of blends, and in recent audits we’ve come across a handful of wines with issues relating to multiple GI labelling.
Have you figured out what the above communities have in common yet? (and we’re not referring to the obvious that they all start with ‘B’…)
The answer we’re looking for is that while grapes are grown near these communities, they aren’t registered Geographic Indications (GIs) and therefore aren’t protected in the same way that registered GIs are for labelling purposes. While Australian wine producers can blend wines from different GIs however they like, if making a labelling claim about the wine origin, Regulation 26 of the Wine Australia Regulations 2018 must be observed.
GIs and labelling
To provide background, Australia’s Geographical Indications (GIs) are classified into states, zones, regions and sub-regions – but this only relates to size. All registered GIs are afforded the same protection and the inclusion of a GI on a label is taken to be a claim, regardless of the context in which it’s used.
Claiming a GI (just like vintage and variety) is completely optional; you don’t have to label with a GI and could just use ‘Australia’. But if you do wish to label a single GI, it’s simple; your wine must comprise at least 850ml/L (i.e. 85 per cent) from the claimed GI. Don’t forget that you must have documentation to support label claims around origin – it’s important to record the most specific GI a wine is entitled to right from the point of fruit intake so that it can be tracked throughout a wine’s processing.
When it comes to multiple GI claims, it can appear a little more complicated:
- you can label a maximum of 3 registered GIs, with a minimum of 5 per cent of any registered GI should you wish to include it
- at least 950ml/L (i.e. 95 per cent) of the wine must be from the GIs claimed, and
- GIs must be presented in descending order of their contribution to the blend (largest to smallest).
Recently our routine audits have uncovered a handful of wines that outline the blend origin (i.e. claim multiple GIs) in their presentation and description. However, not all GIs being claimed are registered ones, meaning that the 95 per cent composition requirement under Regulation 26 isn’t being met.
As an example; if you packaged and presented your wine as being made from 50 per cent ‘Berri’ fruit (Berri being a community within the Riverland GI), 30 per cent Barossa Valley fruit, and 20 per cent Blackwood Valley fruit – you’d only be accounting for half the composition on your packaging and not the required 95 per cent, since ‘Berri’ isn’t a registered GI. Similarly, if you had a blend comprising 50 per cent High Eden and 50 per cent Harcourt Valley (an area within the Bendigo GI around the community of Harcourt), the only GI claim would be High Eden – and since that makes it a single GI claim, at least 85 per cent of the wine would have to be from the registered GI of High Eden to satisfy Regulation 26.
Failing to label GIs correctly in accordance with Regulation 26 contravenes Section 40F of the Wine Australia Act 2013 (misleading descriptions and presentations), which is an offence.
Simple solutions
There’s a few simple solutions you could consider for this potential GI dilemma when presenting your wines. If you’re choosing to claim multiple GIs, either ensure that all the GIs you present in your wine description and presentation are registered ones, or that no registered GIs are presented. In effect, instead of using Ballarat, Berri, Bellarine, Ballandean and Birdwood in conjunction with other registered GIs, use Central Victoria, Riverland, Geelong, Granite Belt and Adelaide Hills (respectively). Or, if the components of your blend all fall within a larger registered GI, you could consider making a single GI claim – for example, a blend made up of at least 85 per cent fruit from the Geelong, Yarra Valley and Mornington Peninsula GIs could be labelled as ‘Port Phillip’ – or ‘Victoria’, or ‘South Eastern Australia’.
Above all, don’t be afraid to contact us if you’re unsure around labelling claims. For any questions about making vintage, variety and origin claims, Wine Australia offers a label opinion service, and is always happy to provide guidance to producers and exporters around what you can and can’t label to stay within the Regulations. Contact our team via labels@wineaustralia.com or (08) 8228 2000.