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Soapbox: Importer labelling by stealth

Published:  20 February, 2024

Miles Corish MW, MD of Milestone Wines, takes issue with ‘a classic case of smoke and mirrors’.

From the tone of several UK press articles, one could be forgiven for assuming that ‘importer labelling requirements’ had been successfully lobbied against – and are subsequently no longer required.

“As of 1 January, several new wine reforms introduced by the government have taken effect, including the removal of importer addresses from wine labels,” as Harpers and others have reported. However, dig a little deeper, and it seems that it’s a classic case of government smoke and mirrors.

In October 2023, the Department for Environment, Food & Rural Affairs (Defra) announced that it would remove the requirement for imported wines to have an importer address on the label – stating that only the name and address of the food business operator (FBO) will need to appear on the label. Some have championed this as a minor victory for the wine trade, others even interpreting it as a victory for consumer choice.

However, if the FBO is based in the UK, Channel Islands or Isle of Man (in other words, most UK wine importers), wines will have to have the FBO on the label. How is the name of the importer any different to the name of the FBO? Surely this is just semantics.

As an importer of global wines (including wines from Europe), essentially we must now arrange for our producers to affix back labels to each bottle (for each shipment) – meaning additional costs and time delays. The only detail that doesn’t need to be included is ‘imported by’, but to all intents and purposes, aside from this omission, we still need to adapt our producers’ packaging to incorporate our ‘importer details’.

In contrast to stock destined for other markets, new UK labelling requirements mean that labels from European producers will have to be different to those being sold in the EU (as they need to be identified by a UK-based FBO). European producers now have the hindrance of creating a specific UK label, adding yet another layer of bureaucracy. Far from maintaining the UK as an attractive destination market, it will do the opposite.

Ambiguity abounds

Seeking clarification around these new regulations on the government website, ambiguity abounds. How are we to decipher wines that are excluded from re-labelling? The extract from the website is as follows:

Wine labelled before 1 January 2024

Wine will not need to be re-labelled to comply with the rules if any of the following apply:

  • It’s already been labelled and is being aged
  • It’s already in the supply chain
  • It was placed on the market before 1 January 2024

Point 1: Does this mean that any wine produced, labelled and in a winery from the 2023 vintage and older is fine to be imported without re-labelling?

Point 2: Does this mean that a wine already in ‘circulation’ but needing to be re-shipped again (irrespective of when the new consignment is bottled and labelled) is exempt from re-labelling? For example, many importers have existing wines in circulation – which are bottled to order before each shipment. Such wines are identical to what’s in the ‘supply chain’, but they are not currently lying labelled (although one can argue, they are being aged). Do these require FBO labelling?

Point 3: What does ‘placed on the market’ mean? Perhaps this is the most ambiguous of the three criteria.

Does this mean ‘within the supply chain’ as above?

Despite the general positive spin following the Defra public consultation, I fail to see how the wine trade seems to have ‘benefited’ from changes to the legislation. It seems to me that excitement surrounding the removal of the term ‘imported by’ has missed the larger point as, clearly, UK-specific label alterations for European wines are now being mandated.

Did the government think that back labels would be changed/added by producers for free?

Some importers are already being charged more for this requirement – which again adds to inflation. From the wine trade’s perspective, once again, more red tape has been imposed – making the UK an even more difficult and undesirable place to trade with.

Far from facilitating a marketplace where UK consumers continue to have access to the widest possible choice of wine from around the world, bureaucracy of this nature will ultimately lead to a reduction of SKUs and a dumbing down of the wine sector. Taken in conjunction with last year’s inflationary increases to duty (and don’t get me started on the proposals for February 2025), perhaps the government’s aim of discouraging UK wine consumption is far less stealthy than its labelling policies…