In the 12 months to December 2018, 6.2 million litres of Australian wine, valued at $26.5 million were exported to Thailand. While this represents less than one per cent of Australia’s export volume, approximately 1100 individual wines were included in the export mix last year; therefore the possible introduction of an expensive new wine analysis and certification requirement poses a risk to continued growth in this market.
Implementation may be imminent
The Thai excise department has modified its initial proposal several times since we were first made aware of its existence early last year, and the latest draft still leaves much ambiguity, but given that the World Trade Organisation has been notified of the proposal, it seems implementation may be imminent.
What we do know is that wines sent to Thailand will not necessarily need to be accompanied by an analysis certificate. Importers can choose to submit samples to a laboratory in Bangkok, rather than require a certificate from their supplier, but given the expense and time constraints associated with that option it is likely many will request the Australian exporter to obtain the relevant certificate.
10 analytes proposed
It can be seen from the draft certificate below that 10 different analytes are proposed. Analysis for the first of these, sulphur dioxide, is routine and should not present a problem to Australian exporters.
One of the others, benzoic acid, is not legally permitted to be added to Australian wine hence it would seem the relevant box could be ticked on the form without performing any analysis. Unless we hear otherwise from Thai authorities, Wine Australia would be prepared to sign the document without analysis being performed for benzoic acid (or its salts).
Of the remainder, two items, sorbic acid or ferrocyanide, could be legally added to Australian wine but Wine Australia intends to accept the statement that the wine does not exceed the relevant maximum requirement provided the exporter declares these substances have not been used during the production of the wine. If, on the other hand, these materials have been used then analysis will be necessary to support the statement that the wine meets the stated limits.
All Australian wine may contain some level of the remaining six items, albeit at levels well below the Thai limits. Hence Wine Australia would accept a self-declaration by the exporter that the wine complies with the Thai limits for these items. The exporter can determine whether or not analysis is needed in order to support that declaration. In the case that the exporter is not the wine producer the declaration must be based on analysis unless the exporter can produce an equivalent certificate provided to them by their supplier.
We have spoken with both the Australian Wine Research Institute (AWRI) and Vintessential laboratories and each can provide further advice regarding the analysis required under this Thai proposal.
What to do if your importer requests a certificate
In summary, if your importer requests a certificate (and you decide to comply), Wine Australia would issue the document based on analysis provided in relation to sulphur dioxide and, if sorbic acid and/or potassium ferrocyanide has been used, then we would also expect analysis for these substances. We would not expect analysis for benzoic acid as exporters declare wine to be compliant with Australian law as part of the export process and, as mentioned above, benzoates are not permitted to be added to Australian wine.
Exporters who did not produce the wine must provide analysis for all parameters other than benzoic acid unless their supplier certifies compliance.
Draft certificate – for reference only
