While all Australian wine must, by default, comply with the Food Standards Code (FSC), specific exemptions exist for exported products. These allowances are critical for producers targeting the ASEAN region, as they accommodate the varying legal frameworks and consumer standards of different countries, from Malaysia to the Philippines. As the fourth instalment in our series on wine exporting, this guide breaks down the key, pre-approved food standards code exemptions to help exporters ensure their products are compliant for their target market.
The Principle of Exemption
Wine Australia may grant an exemption only if it is satisfied that a product’s non-compliance with the domestic code will not compromise the reputation of Australian wine. This principle ensures that flexibility does not come at the cost of quality. It is critical to understand that these exemptions apply exclusively to products destined for export and are not permitted for wine sold within Australia.
Key Exemptions: Labelling and Presentation
For exported products, several FSC rules related to label information are adjusted to align with the requirements of the destination market. The primary exemptions focus on ensuring the label is useful and compliant in the country where it will be sold. Wine Australia has approved the following key labelling exemptions:
- English Language Requirement
- An exemption allows for a translation of the label into the language of the destination market. However, the importer’s name and address, along with the allergen declaration, must be provided in English if requested by Wine Australia.
- Standard Drinks Labelling
- The declaration of standard drinks is not required if the destination market does not mandate it or has different requirements that make the Australian standard irrelevant.
- Pregnancy Warning Labels
- The pregnancy warning logo required for domestic products does not need to be present on labels for exported products, unless the importing country has an equivalent requirement.
- While not necessarily identical to Australia’s pictogram, these countries have laws requiring general health warnings on alcohol, which an exporter must comply with.
- Thailand: The Alcoholic Beverage Control Act requires that locally produced and imported alcoholic beverages carry a graphic and textual health warning. While not exclusively about pregnancy, it is a mandatory health notice.
- Vietnam: The Law on Prevention and Control of Harms of Alcoholic Beverages mandates health warnings on alcohol labels.
- Nutrition Information Panel (NIP)
- In cases where an importing market’s laws demand a different format for the nutrition panel, an exemption from the prescribed Australian format is approved to ensure local compliance.
- Nations such as Singapore, Malaysia, Thailand, and Vietnam have their own specific food labelling regulations. While a full NIP is not always mandatory for wine unless a nutritional claim is made, any nutritional information presented must follow the local format. Singapore‘s “Nutri-Grade” system is a prominent example of a completely different labelling requirement for beverages. In these cases, the exemption allows an exporter to replace the Australian NIP with the locally compliant version.
NOTE: Rules and regulations of the destination countries are subject to changes, which may render parts of the information presented above inaccurate. Please contact us or other relevant authorities for the most up-to-date information.
Key Exemptions: Product Composition and Alcohol
Exemptions also apply to the declared contents and alcohol information of the wine. These adjustments allow products to conform to the specific compositional standards and descriptive norms of the importing country. The most significant exemptions in this category include:
- Allergens Declaration
- The requirement to declare the presence of milk, egg, and fish allergens is exempted if the destination market does not require such declarations. The declaration for sulphites remains mandatory.
- Sulphur Dioxide Composition
- The export of wine that does not comply with the domestic limit for sulphur dioxide (e.g., up to 400 mg/L) may be approved if it meets the rules of the destination market and is not considered a risk to Australian wine’s reputation.
- Alcohol Descriptors and Tolerance
- Descriptors like ‘alcohol free’ or ‘low alcohol’ may be used according to the definitions in the importing country’s laws. For fortified wines, a greater alcohol tolerance between the label and the actual content (e.g., +/- 0.8% in the EU) is permitted to meet international standards.
- Labelling of ‘Light’ Wines
- Claims of ‘light’ wine, referring to lower alcohol content, can omit the standard reference product comparison on the label if the importing market for such wines does not require it.
Conclusion
The Food Standards Code exemptions are practical instruments that enable Australian wine to adapt to diverse global markets. They are not shortcuts, but rather structured allowances that facilitate international trade while protecting the industry’s reputation. It remains the exporter’s responsibility to understand both the Australian export requirements and the specific laws of the destination country to ensure complete compliance before shipment.
With your product fully compliant for your target market, the final step is a flawless delivery. Contact Arc Freights for specialized logistics solutions that protect your wine from origin to destination. Arc Freights is Australia’s leading Freight Forwarder offering QUALITY & RELIABLE logistics services in more than 140 countries. Having plied our expertise in ASEAN for nearly two decades, we are the trusted partner for logistics between Australia and Brunei, Cambodia, Indonesia, Laos, Malaysia, Myanmar, Philippines, Singapore, Thailand, and Vietnam. With expert knowledge, advanced technology, and a commitment to reliability, we provide seamless logistics management, including door-to-door sea freight services, that helps you focus on what matters most—growing your business.
