This guide provides detailed information on the labelling requirements that apply to wine labels in Australia. Information on labelling requirements for export markets are outlined in the Export Market Guides published on the Wine Australia website.
Wine labels are governed by a number of different Commonwealth and State legislation including:
- Wine Australia Act 2013
- Wine Australia Regulations 2018
- Australia New Zealand Food Standards Code
- National Measurement Act 1960
- National Trade Measurement Regulations 2009
- Competition and Consumer Act 2010
- State Food Acts
Mandatory labelling requirements
Name of food (Standard 1.2.2–2)
The Food Standards Code requires labels to include an appropriate name or description of the food. There are no prescribed names but the food must convey the true nature of the product. For example, names such as ‘wine’, ‘chardonnay’, ‘shiraz’ or ‘sparkling wine’ would be sufficient provided that any claimed grape varieties meet the blending rules and that use of any terms defined in the Food Standards Code (i.e. ‘wine’, ‘sparkling wine’, ‘fortified wine’ and ‘brandy’) meet the conditions as summarised in Additives and processing Aids.
Wine products are defined as food containing no less than 700 mL/L (70 per cent) of wine as defined in the Standard, which has been formulated, processed, modified or mixed with other foods such that it is not wine. ‘Wine product’ alone, however, may not be sufficient to convey the true nature of the product. Wine Australia advises that wine products with added water, colours, flavours etc, be labelled as a ‘wine-based beverage’ with added descriptors as needed. Exported wine products are not permitted to claim a geographical indication (other than ‘Australia’) on their labels.
Lot identification (Standard 1.2.2–3)
Identifying your ‘lot’ or batch is mandatory under the Food Standards Code. Lot identifiers are primarily for traceability purposes in the event of a recall or withdrawal. If a product is not lot marked then all product carrying the same label may be compulsorily recalled by health authorities instead of just the affected production run.
For Australia, there’s no prescribed format, but it typically takes the form of an alpha-numeric code. Some wineries use a code that’s modelled on a day/month/year format. Some markets (such as the European Union) require the lot code to commence with the letter L.
The lot identification may be placed anywhere that will be visible after finished packaging and is often stamped on the bottle at the time of bottling. If you have a single product from a single batch, the label itself could be the lot identifier.
Read more about the lot identification here.
Name and address of supplier (Standard 1.2.2–4)
The name and business address of the supplier (defined as the Australian or New Zealand vendor, manufacturer, packer or importer) must be placed on the label. The address must show the road or street number (if any), road or street name, suburb, town, State/Territory (or postcode). Postal addresses (e.g. PO Box or RSD numbers) cannot be used instead of a physical address.
The marking of the name and address is also required under section 4.7 of the National Trade Measurement Regulations 2009.
Registered geographical indications in addresses
Using an address that includes a geographical indication could result in a non-compliant label under the false and misleading description and presentation provisions of the Act. An address can contain a registered GI in circumstances where the fruit was not sourced from that GI, but it is required to identify the location of the place in which the wine was manufactured. This doesn’t include cellar door or vineyard addresses, and the way in which the address is displayed must not be misleading as to the origin of the grapes.
If your wine isn’t sourced from the GI used in the address, this flow chart will help you determine if GI use may be considered either false or misleading.
Read more about registered GIs in addresses here.
Mandatory advisory statements (allergens) (Standard 1.2.3–4)
Certain foods and ingredients can cause severe allergic and other adverse reactions in some people. The Food Standards Code requires these to be declared on labels when they are present in food.
On 25 February 2021 the Code was amended to introduce new requirements for the labelling of allergens in food.
In accordance with the Code, allergen information must be declared using the required name of the food in simple, plain English terms.
Businesses have 3 years from 25 February 2021 to implement the new requirements. During this transition period, food businesses can comply with either the existing allergen declaration requirements in the Code (which do not specify the wording to be used), or the new requirements.
A 2-year stock-in-trade period will follow the transition period. Any food packaged and labelled with existing allergen declarations before the end of the transition period may be sold for up to 2 years after the end of the transition period.
The required names as applicable to wine and wine products must follow the wording as outlined in the table below:
|Food ||Required name for declaration |
|Added sulphites in concentrations of 10 mg/kg or more ||sulphites |
|Egg ||egg |
|Milk ||milk |
Other than the required name of the food for the declaration, the format is not otherwise prescribed for standardised alcoholic beverages (including wine and wine product). For all other foods, the statement will be required to appear in a bold ‘contains’ statement e.g. ‘contains sulphites’ from 25 February 2024.
Wine is exempt from the requirement to declare isinglass derived from fish on the mandatory declaration.
Be aware that some allergenic substances can come from obscure sources. For example, some caramels used in the production of fortified wines are produced from wheat (gluten), and some ‘technical’ corks may be manufactured using casein-based glues that may leach into the product. Refer to Schedule 9 of the Code for advice on the mandatory declarations for other foods.
Wine manufacturers are advised to seek written advice from suppliers as to the source of any additives, processing aids or packaging or other products that potentially could be the source of allergenic substances. Sources of allergenic substances could include failure to adequately clean production machinery, failure to adequately segregate allergenic substances in storage or on the production line, accidental or subversive addition of substances, or the failure of suppliers to identify such substances in their products.
Exporters should take particular note of any allergen labelling requirements in the destination market as some markets specify the format and language. In some export markets allergens labelling for wine is not required. Wine Australia has issued a broad exemption from the requirement to declare the presence of egg and milk in markets where allergens declarations are not mandatory. The exemption does not extend to the declaration of added sulphites which must be declared on export labels regardless. Refer to the Export Market Guides for further assistance.
Sulphite and preservative free wines
Even if no sulphur dioxide has been added, care must be taken in any claim that a wine contains ‘zero sulphur’ or is ‘preservative free’. Yeast can naturally produce sulphites during the fermentation process. ‘Preservative free’ should only be claimed if there are no quantifiable levels of sulphur dioxide in the wine. If there is less than 10 mg/kg of naturally occurring sulphur dioxide a claim such as ‘no added preservatives’ may be acceptable.
Statement of alcohol content (Standard 2.7.1–3)
An alcohol statement is mandatory for foods containing more than 0.5% alcohol by volume. For a food (including an alcoholic beverage) that contains more than 1.15% alcohol by volume, the statement must be expressed as the percentage of alcohol by volume (e.g. ‘13.5% alc/vol’).
For an alcoholic beverage that contains not less than 0.5% and not more than 1.15% alcohol by volume, the alcohol content must be expressed in words to the effect ‘contains not more than x% alcohol by volume’.
An alcoholic beverage which contains more than 1.15% alcohol by volume must not be represented as a ‘low alcohol’ (or words to a similar effect) beverage.
The alcohol content statement must be accurate to within:
- 1.5% alc/vol for wine, sparkling wine and wine products containing more than 6.5% alc/vol
- 0.5% alc/vol for spirits, brandy and fortified wine, and
- 0.5% alc/vol for all other alcoholic beverages containing more than 1.15% (to less than 6.5% alc/vol).
It is important to note that the above information relates to Australian and New Zealand requirements only and the tolerance for the alcohol statement may differ for export markets. Further information relating to alcohol labelling tolerance for export markets can be found here and in the Export Market Guides.
Standard drink statement (Standard 2.7.1–4)
A standard drink is defined as the amount of beverage which contains 10 grams of ethanol, measured at 20°C. The label on a beverage or a food capable of being consumed as a beverage, which contains more than 0.5% alcohol by volume, measured at 20°C, must include a statement of the approximate number of standard drinks in the package:
- in the case of packages containing 10 or less standard drinks, accurate to the first decimal place
- in the case of packages containing more than 10 standard drinks, accurate to the nearest whole number of standard drinks.
The formula for the calculation is:
container volume (litres) x % alcohol/vol (mL/100mL) x 0.789 (specific gravity of ethanol) = number of standard drinks.
For example, a 750mL bottle which contains 14% alc/vol would be calculated:
0.75 x 14 x 0.789
= 8.28, rounded to one decimal place
= 8.3 standard drinks.
The statement should be worded ‘Contains approximately 8.3 standard drinks’. Alternatively, the approved Australian Grape & Wine logo may be used.
Note, while the standard drink concept is accepted and well-understood in Australia, this is not necessarily the case in other markets and a standard drinks statement may not be allowed in some export destinations. Wine Australia has issued a broad exemption from the requirement to label standard drinks for exported grape products. Markets that do not permit Australian standard drinks on export labels include the United States and Canada. It is acceptable to label standard drinks on Australian labels in the EU and UK markets due to the EU-Australia Wine Agreement.
Pregnancy warning labels (Standard 2.7.1–8)
The Food Standards Code was amended on 31 July 2020 to require packaged alcoholic beverages with greater than 1.15% alcohol by volume to display a pregnancy warning mark.
Downloadable labels can be obtained from the FSANZ website.
There is a three-year transition period, ending 31 July 2023, for producers to start including the pregnancy warning mark on their packaging. Stock labelled after 31 July 2023 must include the mark, but stock labelled prior to 31 July 2023 may be exhausted after this date without adding the mark.
The size requirements for an individual unit (e.g. a bottle, can or cask) are shown in table 1 below. ‘Size of type’ means the measurement from the base to the top of a letter or numeral.The size requirements for an individual unit (e.g. a bottle, can or cask) are shown in table 1 below. ‘Size of type’ means the measurement from the base to the top of a letter or numeral.
Table 1: Warning mark requirements for individual units
|Individual unit volume ||Warning label to be displayed ||Size of pictogram ||Size of type of signal words ||Size of type of the statement |
|Less than 200mL ||Pictogram only ||At least 8mm diameter ||Not applicable ||Not applicable |
|Between 200mL and 800mL ||Full pregnancy warning mark ||At least 6mm diameter ||At least 2.1mm ||At least 1.6mm |
|More than 800mL ||Full pregnancy warning mark ||At least 9mm diameter ||At least 2.8mm ||At least 2.1mm |
The outer packaging of prescribed alcoholic beverages that will be used for retail sale (e.g. presentation box, multi-unit wrap or 6-pack/12-pack cartons) also require a pregnancy warning mark. If outer packaging doesn’t obscure the individual unit (e.g. a cellophane wrap or similar) then it doesn’t require a pregnancy warning mark. Note, this requirement only applies to outer packaging for retail sale to the consumer rather than boxes solely used for transport.
The size requirement for outer packages is shown in table 2 below.
Table 2: Warning mark requirements for outer packaging (for retail sale)
|Package type ||Warning label to be displayed ||Size of pictogram ||Size of type of signal words ||Size of type of the statement |
|Outer package containing only one inner individual unit, with a volume not more than 200mL ||Pictogram only ||At least 8mm diameter ||Not applicable ||Not applicable |
|Outer package containing either: |
- one individual inner unit over 200mL
- multiple inner units, more than 200mL each
- multiple inner units, not more than 200mL each
|Full pregnancy warning mark ||At least 11mm diameter ||At least 3.5mm ||At least 2.7mm |
Wine Australia has issued a broad exemption from the pregnancy warning label requirement for exported grape products.
Country of origin statement (CCA ss 24–25)
Country of origin labelling requirements are regulated by the Country of Origin Food Labelling Information Standard 2016 made under the Competition and Consumer Act 2010, administered by the Australian Competition and Consumer Commission (ACCC).
Alcoholic beverages are one of a small number of non-priority foods that are exempt from the country of origin food labelling system. For non-priority foods, the use of the standard marks (see below) are voluntary rather than mandatory. Non-priority foods must carry a country of origin text statement about where the food was grown, produced, made or packed.
Imported foods must also display country of origin information. Like non-priority foods, imported foods only have to carry a text statement.
Section 8 of the Country of Origin Food Labelling Information Standard defines the terms ‘grown, ‘produced’ and ‘made’ as follows:
(a) a food or ingredient was grown in a country if it:
- was materially increased in size or materially altered in substance in that country by natural development; or;
- germinated or otherwise arose in, or issued in, that country; or
- was harvested, extracted or otherwise derived from an organism that has been materially increased in size, or materially altered in substance, in that country by natural development;
(b) a food consisting of more than one ingredient is also grown in a country if:
- each of its significant ingredients was grown in that country; and
- all, or virtually all, of the processing occurred in that country.
made: a food was made in a country if it underwent its last substantial transformation in that country.
produced: a food was produced in a country if:
(a) each of its significant ingredients was grown or otherwise wholly obtained in that country; and
(b) all, or virtually all, of the processing occurred in that country.
In addition, section 24 of the Regulations requires that if a wine is made from grapes grown in more than one country, the description and presentation must identify the proportion from each country. The 85 per cent rule for single-GI claims does not apply to the country of origin.
If packaging a multiple-origin wine, a statement such as ‘Wine packaged in Australia from X per cent Australian and Y per cent [country B] produce’ would satisfy both domestic and export requirements.
For export, it’s recommended that country of origin labelling is separated from any GI claim. For example, statements such as ‘Wine of Western Australia’ or ‘Wine of Margaret River, Australia’ should be avoided. Note that for export to many countries the format of the ‘country’ statement is prescribed. Many producers now elect to use the EU format that requires the word wine in combination with the country claim (e.g. ‘Wine of Australia’).
Volume statement (National Trade Measurement Regulations)
Wine in standard size containers (50 mL, 100 mL, 187 mL, 200 mL, 250 mL, 375 mL, 500 mL, 750 mL, 1 litre, 1.5 litres, 2 litres, 3 litres, or a larger quantity of whole litres), is exempt from the general requirement that measurement markings appear on the principal display panel.
Accordingly, Australian wines may indicate the volume on any label, however, exporters should be aware of the ‘single field of vision’ concept applicable in World Wine Trade Group member countries and the European Union and UK.
The statement of quantity must be:
- of at least the prescribed minimum character height (refer to the table below)
- close to the name or brand of the product
- at least 2 mm from the edges of the package
- at least 2 mm in any direction from any graphics or written copy
- in metric units and in clear English
- clear and stamped or printed in distinct colour contrast to the background graphics.
Minimum print sizes depending on the largest dimension of the container are also applicable. In the case of a bottle, this is the bottle height in millimetres. For a cask, it is the measurement of the longest edge. For a standard 750 mL wine bottle, the minimum character height is 3.3 mm.
|Largest package dimension ||Minimum print height* |
|<120 mm ||2.0 mm |
|120 to <230 mm ||2.5 mm |
|230 to <360 mm ||3.3 mm (standard 750mL bottle) |
|>360 mm ||4.8 mm |
* Minimum print height applies to the shortest character in the statement
Accepted units for the volume statement are L (litre), dL (decilitre), cL (centilitre) or mL (millilitre).
Additional labelling considerations
Legibility (Standard 1.2.1–24)
There are no print size specifications under the Food Standards Code other than the general legibility requirements which requires any mandatory statement to be in English and be legible and prominent so as to contrast distinctly with the background of the label.
Date marking (Standard 1.2.5)
A best-before-date is mandatory on products with less than two years’ shelf life. The Food Standards Code defines the ‘best before’ date as:
the date which signifies the end of the period during which the intact package of food, if stored in accordance with any stated storage instructions, will remain fully marketable and will retain any specific qualities for which express or implied claims have been made.
In the case of wine and wine product, this normally would only apply where plastic or other non-glass packaging is used and where a limited shelf life (less than two years) is likely. However, if the description and presentation of the wine claims or implies certain qualities (such as freshness, drink whilst young etc.) then a ‘best before’ date is required unless any such claims would remain valid for at least two years.
The date must appear in the format ‘best before [month] ]year]’ e.g. ‘best before Dec 21’ or ‘best before 12 21’ and the label must include a statement of any specific storage conditions required to ensure the food will keep for the specified period.
Nutrition and health claims (Standard 1.2.7–4)
The Food Standards Code prohibits health claims and nutrition content claims in respect of a product that contains more than 1.15% alcohol by volume with the exception of energy, carbohydrate or gluten content claims.
A health claim means a claim which states, suggests or implies that a food or a property of food has, or may have, a health effect. Nutrition content claims are about the presence or absence of certain nutrients or substances in a food such as biologically active substances (e.g. resveratrol, polyphenols, antioxidants), protein, sodium and vitamins.
If you make an energy or carbohydrate content claim you must include a nutritional information panel (NIP) on the label. Gluten free claims do not require a NIP.
Comparative claims such as ‘lighter in energy’ or similar must additionally indicate the reference product. The difference between the amount of the property of food in the claimed food and the reference food must be at least 25% lower e.g. ‘Lighter in calories wine – at least 25% less calories compared to [2020 brand Shiraz]’.
Read more about nutrition content and health claims here.
If you want to make a nutrition content claim, this flow chart will help determine whether your claim meets the requirements.
Australian Consumer Law
Any product sold in Australia is subject to the Australian Consumer Law, which prohibits conduct in trade or commerce which is misleading or deceptive or likely to mislead or deceive. See the ACCC’s guidance on making premium claims and Green Marketing Guide. In short, any claims must be honest, accurate and able to be substantiated. Certain wine label claims that would come under these provisions include statements such as ‘single vineyard’, ‘barrel fermented’, ‘estate bottled’, ‘established in xxxx’ etc.
Refer to the Wine Australia website for further information on voluntary labelling terms.