Recent developments in alcohol labelling
4 July 2023
Mark Riley, International Regulatory Affairs Team manager
Hold the booze – it can be dizzying enough trying to get your head around all the changes to how our alcohol labels
need to be presented. This blog aims to clarify and simplify some of the more recent changes and developments.
Implementation of a deposit return scheme for beverage containers in Scotland has been pushed back to October 2025
at the earliest; at which time integration, to some degree, with deposit return schemes (DRSs) in other devolved nations can be expected.
Although Scotland’s DRS was not initially intended to require any specific labelling (other than the barcode), the English, Welsh and Northern
Irish governments have all indicated their intention1 to require both a code (barcode or QR code) for the practical implementation
of the scheme, as well as a specific DRS logo to alert consumers that the item falls within the scheme.
Declaration of ABV
It is now permissible in Great Britain2 to use the alternative indication “X% alc/vol”, rather than the
more familiar “[alc] X% vol.” to indicate alcoholic strength (alcohol by volume, or ‘ABV’). This change applies to all alcoholic beverages,
and was introduced as a result of the recent free trade agreement with New Zealand. There is no requirement to change from the old format for
declaration of alcoholic strength, but the alternative option now exists for GB producers and importers.
Changes to wine labelling
Retained Commission Delegated Regulation (EU) 2019/33 required that, with certain exception, where two or more grape
varieties are named on a label, 100% of the product must have been made with these varieties. This has now been reduced to require that only
95% is derived from the named varieties3. The requirement remains 100% in the EU.
Defra is currently consulting4 on a range of issues relating to wine production, packaging, labelling and
certification. On the labelling side, one of the proposals is to remove the requirement for “importer” or “imported by” to precede the
importer in GB, and to replace this with a requirement to list the Food Business Operator as with other food products. As the EU currently
requires “importer” or “imported by” to precede the EU importer name and address, the proposed changes would permit both EU and GB addresses
on a single label.
Mandatory labelling of ingredients and nutrition information will come into force on 8 December 20235. The
option does exist to limit the on-label nutrient declaration to energy only and to present the full nutrition declaration and list of
ingredients by electronic means, provided that the direct link avoids any collection or tracking of user data and does not provide information
for marketing purposes. This doesn’t affect requirements for on-label allergen listing.
The initiative on mandatory nutrition and ingredient labelling for alcoholic beverages other than wine remains
ongoing at the time of writing6.
Low alcohol and de-alcoholised wine
Post-Brexit amendments7 to Regulation (EU) No 1308/2013 allows wine in the EU, once the characteristics
specified for the particular grapevine product, including minimum/maximum alcohol content, have been developed, to be de-alcoholised (<0.5%
ABV) or partially de-alcoholised (>0.5% ABV) and labelled as wines with the appropriate descriptor.
Although these changes have not yet been incorporated into retained EU law in GB, proposals in the previously mentioned
Defra consultation8 would not only allow for the de-alcoholisation or partial de-alcoholisation of wines, but also allow for the
production of wines naturally lower in ABV.
The Commission proposal for health warnings on labels of alcoholic beverages is anticipated before the end of the
year. In the meanwhile, the smooth progress of the Irish Regulations9 (made under Section 12 of the Public Health (Alcohol) Act
2018) on labelling of alcohol products, which include health warnings, a declaration of energy per container and the requirement to list
alcohol content in grams as well as percentage alcohol by volume, caught many observers by surprise. These Regulations will now come into
force on 22 May 202610.
While the much-anticipated revision to the Department of Health and Social Care’s Low Alcohol Descriptors Guidance11
has not yet materialised, we have seen the first indications of development in this area with the publication of the outcome of the
Defra-commissioned qualitative research into No/Low alcohol labelling12. The conclusions suggest that current regulations limiting
the use of spirit categories such as “gin” on alcohol-free spirits may have some impact on the uptake of these products, particularly where
they are produced by SMEs who don’t have the brand recognition to create obvious parallels with a traditional spirit range. However, when it
comes to how the term “alcohol-free” should be defined, it seems there is a gap between industry, who prefer a 0.5% ABV threshold, and the
consumer, who expect the term to refer to a complete absence of alcohol.
How we can help
Our experienced team of regulatory experts can help you ensure that your products are compliant with the legislative
requirements of your target market. We offer a valuable, extensive and authoritative information and advisory service to help clients stay
compliant with food regulations in more than 80 countries.
We are also the UK's leading centre for brewing research, covering all matters related to beer, wine and spirit
development, production and analysis.
For support with the development or regulatory compliance of your alcoholic, no/low alcohol or other food or beverage
products, get in touch. Whatever challenge you are working on, we can help you get the answers you need.
How can we help?
If you’d like to find out more about alcohol labelling, contact our support team to find out how
we can help.
We can help with all things beer, wine and spirit development, production and analysis – view the
service pages to find out more.
- 1 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1130296/DRS_Government_response_Jan_2023.pdf
- 2 The Alcoholic Beverages (Amendment) (England) Regulations 2023, The Alcoholic Beverages, Fruit and Vegetables (Miscellaneous Amendment) (Scotland) Regulations 2023, The Alcoholic Beverages (Amendment) (Wales) Regulations 2023
- 3 The Alcoholic Beverages (Amendment) (England) Regulations 2023, The Alcoholic Beverages, Fruit and Vegetables (Miscellaneous Amendment) (Scotland) Regulations 2023, The Alcoholic Beverages (Amendment) (Wales) Regulations 2023
- 4 https://consult.defra.gov.uk/alcoholic-drinks-geographical-indications-team/consultation-wine-reform/
- 5 Regulation (EU) 2021/2117
- 6 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13028-Food-labelling-revision-of-rules-on-information-provided-to-consumers-for-alcoholic-beverages_en
- 7 Regulation (EU) 2021/2117
- 8 https://consult.defra.gov.uk/alcoholic-drinks-geographical-indications-team/consultation-wine-reform/
- 9 S.I. No. 249/2023 - Public Health (Alcohol) (Labelling) Regulations 2023
- 10 S.I. No. 248/2023 - Public Health (Alcohol) Act 2018 (Commencement) Order 2023
- 11 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/763840/low-alcohol-descriptors-guidance.pdf
- 12 https://randd.defra.gov.uk/ProjectDetails?ProjectId=21229