In a raft of wine reforms, communicated in October, the Department for Environment, Food and Rural Affairs (Defra) removed the requirement for wines imported from the EU to have an additional UK importer label. The initial requirement was a direct consequence of Brexit, and was set to come in when the transition period finishes, at the end of 2023.
The Wine and Spirit Trade Association (WSTA) has been working with government to introduce wording used in the food industry that would allow both EU and UK addresses on a single label.
Following a consultation, Defra announced that the UK Food Business Operator (FBO), responsible for ensuring all legal requirements are met, will need to be identified on packaging. This is already the standard requirement for food products, Defra said.
So, what does that mean?
Simon Stannard, director of policy at the WSTA, said that while the FBO system will still require some admin changes, it provides greater flexibility for the trade because an FBO can be a UK business responsible for producing, importing or marketing a product. He said the definition of an FBO is “not prescriptive”.
“From January, wines from the EU – like food – will have to have the details of a business based in the territory in which they are sold,” Stannard said. “This business is responsible for the product.
“EU producers can put their details on the label, along with a UK address on the same label,” he said, which would usually be their UK importer.
“Importers already do this for non-EU wine,” Stannard added, highlighting the use of often secondary labels on bottles from Australia, for example.
Although the FBO measure is less complicated than the alternative, Stannard said that a change of FBO (the importer or marketer, for example) would mean having to change the labels.
Retailers that form cooperatives to buy wine will have to choose one business to be the FBO for the purposes of the label.
He said the new rules may shake up the industry in terms of how people do business – and placing FBO information on the label will become part of commercial conversations and transactions.
In a recent note to the trade, the WSTA said the position is less straightforward for products produced or bottled in the UK, and for sparkling wines, whether produced in the UK or imported.
“Defra officials are sympathetic to introducing further amendments in future that will align the whole wine regime more closely with the FBO regime for other products,” the note said.
Overall, the new system is not as easy as it was when the UK was part of the EU. But the FBO system is already used by the food industry and will hopefully remove at least some red tape. It’s also worth noting that the new rules apply to goods placed on the market from January 1. Goods already on the market won’t need to change labels.