The record keeping requirement on bottlers is the same whether they are packaging their own wine or someone else’s.
In summary, packagers must:
- make a record upon receipt of a customer’s wine that includes details of the composition of that wine (within three days of receipt)
- make records if they alter the wine in any respect (such as blending the wine or adding anything to it), and
- keep a record of the supplier of the wine and to whom the wine is dispatched.
In order for packagers to make an accurate record, a record must be supplied to them for the received wine. A supplier has an obligation to provide a record containing LIP details on the same day that the wine is supplied.
Packagers can insist that their customers provide them with records that substantiate vintage, variety and geographical Indication claims made on the labels that will be affixed.
Failure to supply, make or keep sufficient records contravenes theWine Australia Act 2013. Criminal penalties could apply and the sale and export of the affected wine could be prevented.
Frequently asked questions
I lease the bulk storage on my site to another company. Do I need to make LIP records?
No, provided you do not perform any operations on the wine (including loading and unloading), then the obligation to keep records is on the lessee.
No vintage, variety or geographical indication claim will be made on the label. Do I still need to supply a record of the compositional breakdown to my packaging facility?
The information you obtain should be as specific as the information on the label. For example, if the label describes the wine as a non-vintage red, with the only origin statement being ‘Australia’, you only need to obtain that level of detail. On the other hand, if the label claim is ‘2016 Barossa Valley Shiraz’, you need to obtain LIP documentation supporting that claim.
As a packager, I am blending a client’s wine. Do I need to recalculate the vintage, variety and geographical indication composition of the blend?
Yes, the composition of the new blend must be calculated from the records supplied to you for each component of the blend and the volumes from your own record for the operation.
As a packager, my customer won’t provide me with LIP documentation. What should I do?
Insist on it. It is a legal obligation for customers of contract packaging facilities to provide this information. If they do not, contact Wine Australia’s auditors
Photo: Ewen Bell / Wine Australia