Product registration
Licensed exporters may apply to Wine Australia through WALAS for the approval of grape products for export from Australia.
The product registration application must indicate:
- the vintage, variety and origin composition of the grape product
- the vintage, variety and origin claimed on the label of the grape product (packaged product only)
- the analytical details of the grape product, and
- the destination market of the grape product.
In deciding whether to approve a grape product for export, Wine Australia must consider:
- whether the grape product complies with the Food Standards Code
- whether the grape product is sound and merchantable, and
- whether the description and presentation of the grape product is appropriate
- having regard to the requirements of the Act, other Australian laws, and the laws of other countries.
Analysis is checked in WALAS to ensure compliance with any limits specified in the Food Standards Code. Label claims are checked against the product composition to ensure the claims meet the blending rules pertaining to vintage, variety and origin. For packaged products, the post-bottling/packaging analysis must be submitted.
The application must also indicate whether the label makes any organic or biodynamic claims as such products must comply with the Export Control Act 2020 administered by the Department (see Organic goods certificate).
Approved packaged products are issued a PP number and approved bulk products are issued with a PB number.
In circumstances where Wine Australia is not satisfied that the grape product meets the requirements of the Act, other Australian laws, or the laws of other countries, Wine Australia may refuse to approve the grape product for export, or revoke approval of the grape product for export. It is also open to Wine Australia to impose a condition that limits the countries to which the export is approved.
Prior to issuing export approval of a grape product, it is open to Wine Australia to request information from the exporter in accordance with section 16 of the Regulations to satisfy it that the grape product is compliant with the compositional and labelling requirements of Australia and of the importing country.
Associated exporter
An exporter may authorise another exporter to ship their approved products by nominating them as an associated exporter in WALAS.
An exporter can invite another exporter to be their associated exporter by clicking on the ‘Invite an associated exporter’ button in WALAS. You will need to obtain the exporter ID from the associated exporter before starting this process.
After the invitation has been accepted by the associated exporter you can grant access to specific labels and volumes of wine by clicking on ‘Link products to an associated exporter’.
Associations can be ended through WALAS at any time.
Food Standards Code exemptions
Unless an exemption has been granted by Wine Australia, grape products exported from Australia are required to comply with the requirements set out in the Food Standards Code (as outlined in Labelling and Additives and processing aids). In accordance with section 14(3) of the Regulations, Wine Australia may only provide an exemption if it is satisfied that the way in which the grape product does not comply with the Food Standards Code will not compromise the reputation of Australian grape products.
The table below sets out the broad exemptions to compliance with the Food Standards Code that have been approved by Wine Australia. Note that the exemptions apply to exported products only, they do not apply to products sold domestically.
| Exemption | Food Standards Code reference | Details of exemption | Additional notes |
|---|---|---|---|
| English language requirement | Standard 1.2.1–24 specifies that any words required by the Food Standards Code must be in English. | Provided a translation of the relevant label has been provided to Wine Australia and clearly identified against a product registered in WALAS, the following information may be provided in the importing country’s language, rather than in English:
| |
| Standard drinnks labelling | Standard 2.7.1–4 requires a statement of the approximate number of standard drinks in foods that are capable of being consumed as a beverage and which contains more than 0.5% alcohol by volume. | The declaration of the standard drinks statement required under Standard 2.7.1–4 of the Food Standards Code is not mandatory for grape products exported from Australia unless the destination market requires such a declaration. | Many markets either do not require standard drinks labelling or require standard drink, serves, or the like to be called out in different formats to that prescribed under the Food Standards Code. |
| Allergens declaration | Standard 1.2.3–4 requires a mandatory declaration of the presence of certain foods or derivatives of foods listed in the table to Schedule 9–3. For wine, this includes added sulphites in concentrations of 10 mg/kg or more, egg and milk. | The declaration of the presence of egg and milk is not mandatory for grape products exported from Australia unless the destination market requires such a declaration. In markets where other allergens declarations are required, the declaration may be presented in the format specified under the legislation of the importing country. The exemption does not extend to the declaration of added sulphites which must be declared on export labels regardless. | |
| Pregnancy warning labels | Standard 2.7.1–8 requires that from 31 July 2023 prescribed alcoholic beverages above 1.15% alcohol by volume must display the pregnancy warning mark on the product label and on outer packaging that will be used for retail sale. | Exported grape products do not need to be presented with the pregnancy warning label outlined in Standard 2.7.1–8 unless it is a requirement of the importing country. | The pregnancy warning logo (which forms a component part of the pregnancy warning mark) is mandatory in France. Use of the logo is not acceptable in markets that already prescribe pregnancy or other health warnings such as the United States. |
| Low and no alcohol descriptors | Standard 2.7.1–5 restricts representations of low alcohol to alcoholic beverages which contain no more than 1.15% alcohol by volume. Standard 2.7.1–7 states that food containing alcohol must not be represented in a form which expressly or by implication suggests that the product is a non-alcoholic beverage. | In circumstances where an importing country’s laws apply different definitions for low and no alcohol descriptors, grape products exported from Australia may be represented using those descriptors provided the product meets the definitions under the importing country’s laws. | For example, in the UK, drinks from which the alcohol has been extracted and containing no more than 0.05% alcohol by volume may be represented as ‘alcohol free’ (but not non-alcoholic) and grape products with 1.2% alcohol by volume or less may be represented as ‘low alcohol’. |
| Sulphur dioxide composition | Standard 4.5.1 provides that wine, sparkling wine and fortified wine must contain no more than 250 mg/L in total of sulphur dioxide in the case of products containing less than 35 g/L of sugars, or 300 mg/L in total of sulphur dioxide in the case of other products. | The export of wine that does not comply with the sulphur dioxide limits set out in Standard 4.5.1 may be approved provided the grape product meets the rules of the destination market and is not considered to be a risk to the reputation of Australian wine. | |
| Nutritional information panel | Standard 1.2.8 requires a Nutrition Information Panel (NIP) for standardised alcoholic beverages when a claim requiring nutrition information has been made on the label. Section 1.2.8-6(2) states that the NIP must be set out in the prescribed format in section S12-2. | In circumstances where the importing market’s laws require an alternative NIP be provided on the label, grape products will be approved for export from Australia if they contain the importing market format of the NIP instead of the format prescribed in the Food Standards Code. | The Food Standards Code only requires a NIP on the label of standardised alcoholic beverages in circumstances where a nutrition claim, such as calorie content, has been made on the label. |
| Label alcohol tolerance | Standard 2.7.1 requires Australian fortified wine to be labelled with an alcohol statement within +/-0.5% of the actual alcohol of the wine. In some export markets there is a greater tolerance permitted between label and actual alcohol for fortified wines, for example in the European Union where the tolerance is +/-0.8% alcohol. | The label alcohol of fortified wines may be outside of the +/-0.5% tolerance required in Standard 2.7.1 provided it meets the tolerance of the importing market i.e., European Union permit +/-0.8% tolerance between label and actual alcohol. | |
| Labelling of ‘Light’ wines (lighter in alcohol) | ‘Light alcohol’ claims can be made in relation to wine. Such claims do not trigger the need for a nutrition panel, as these are not considered nutrition content claims. They do, however, under section 1.2.7—16 of the Food Standards Code require the inclusion of a reference product and the amount by which the light wine is lower in alcohol than the reference. | ‘Light’ wines, which are lower in alcohol, can omit the reference product comparison, required under FSC 1.2.7-16, provided the comparison is not a requirement of the importing market for such wines. | Light’ wines in this exemption only refers to lighter alcohol. Any other ‘light’ or ‘lighter’ claims, in relation to energy or nutrition content, does require a reference product comparison as well as a Nutrition Information Panel on the label. |