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Food Standards Code exemptions
Food Standards Code exemptions
Unless an exemption has been granted by Wine Australia, grape products exported from Australia are required to comply with the requirements set out in the Food Standards Code (as outlined in labelling and additives and processing aids). In accordance with section 14(3) of the Regulations, Wine Australia may only provide an exemption if it is satisfied that the way in which the grape product does not comply with the Food Standards Code will not compromise the reputation of Australian grape products.
The table below sets out the broad exemptions to compliance with the Food Standards Code that have been approved by Wine Australia. Note that the exemptions apply to exported products only, they do not apply to products sold domestically.
| Exemption | Food Standards Code reference | Details of exemption | Additional notes |
|---|---|---|---|
| English language requirement | Standard 1.2.1—24 specifies that any words required by the Food Standards Code must be in English. | Provided a translation of the relevant label has been provided to Wine Australia and clearly identified against a product registered in WALAS, the following information may be provided in the importing country’s language, rather than in English:
| |
| Standard drinks labelling | Standard 2.7.1—4 requires a statement of the approximate number of standard drinks in foods that are capable of being consumed as a beverage and which contains more than 0.5% alcohol by volume. | The declaration of the standard drinks statement required under Standard 2.7.1—4 is not mandatory for grape products exported from Australia unless the destination market requires such a declaration. | Many markets either do not require standard drinks labelling or require standard drink, serves, or the like to be called out in different formats to that prescribed under the Food Standards Code. |
| Allergens declaration | Standard 1.2.3—4 requires a mandatory declaration of the presence of certain foods or derivatives of foods listed in the table to Schedule 9–3. For wine, this includes added sulphites in concentrations of 10 mg/kg or more, egg and milk. | The declaration of the presence of egg and milk is not mandatory for grape products exported from Australia unless the destination market requires such a declaration. In markets where other allergens declarations are required, the declaration may be presented in the format specified under the legislation of the importing country. The exemption does not extend to the declaration of added sulphites which must be declared on export labels regardless. | |
| Pregnancy warning labels | Standard 2.7.1—8 requires that from 31 July 2023 prescribed alcoholic beverages above 1.15% alcohol by volume must display the pregnancy warning mark on the product label and on outer packaging that will be used for retail sale. | Exported grape products do not need to be presented with the pregnancy warning label outlined in Standard 2.7.1—8 unless it is a requirement of the importing country. | The pregnancy warning logo (which forms a component part of the pregnancy warning mark) is mandatory in France. Use of the logo is not acceptable in markets that already prescribe pregnancy or other health warnings such as the United States. |
| Low and no alcohol descriptors | Standard 2.7.1—5 restricts representations of low alcohol to alcoholic beverages which contain no more than 1.15% alcohol by volume. Standard 2.7.1—7 states that food containing alcohol must not be represented in a form which expressly or by implication suggests that the product is a non-alcoholic beverage. | In circumstances where an importing country’s laws apply different definitions for low and no alcohol descriptors, grape products exported from Australia may be represented using those descriptors provided the product meets the definitions under the importing country’s laws. | For example, in the UK, drinks from which the alcohol has been extracted and containing no more than 0.05% alcohol by volume may be represented as ‘alcohol free’ (but not non-alcoholic) and grape products with 1.2% alcohol by volume or less may be represented as ‘low alcohol’. |
| Sulphur dioxide composition | Standard 4.5.1 provides that wine, sparkling wine and fortified wine must contain no more than 250 mg/L in total of sulphur dioxide in the case of products containing less than 35 g/L of sugars, or 300 mg/L in total of sulphur dioxide in the case of other products. | The export of wine that does not comply with the sulphur dioxide limits set out in Standard 4.5.1 may be approved provided the grape product meets the rules of the destination market and is not considered to be a risk to the reputation of Australian wine. | |
| Nutritional information panel | Standard 1.2.8 requires a Nutrition Information Panel (NIP) for standardised alcoholic beverages when a claim requiring nutrition information has been made on the label. Standard 1.2.8—6(2) states that the NIP must be set out in the prescribed format in Schedule S12-2. | In circumstances where the importing market’s laws require an alternative NIP be provided on the label, grape products will be approved for export from Australia if they contain the importing market format of the NIP instead of the format prescribed in the Food Standards Code. | The Food Standards Code only requires a NIP on the label of standardised alcoholic beverages in circumstances where a nutrition claim, such as calorie content, has been made on the label. |
| Label alcohol tolerance | Standard 2.7.1 requires Australian fortified wine to be labelled with an alcohol statement within +/-0.5% of the actual alcohol of the wine. In some export markets there is a greater tolerance permitted between label and actual alcohol for fortified wines, for example in the European Union where the tolerance is +/-0.8% alcohol. | The label alcohol of fortified wines may be outside of the +/-0.5% tolerance required in Standard 2.7.1 provided it meets the tolerance of the importing market i.e., European Union permit +/-0.8% tolerance between label and actual alcohol. | |
| Labelling of ‘Light’ wines (lighter in alcohol) | ‘Light alcohol’ claims can be made in relation to wine. Such claims do not trigger the need for a NIP, as these are not considered nutrition content claims. They do, however, under Standard 1.2.7—16 require the inclusion of a reference product and the amount by which the light wine is lower in alcohol than the reference. | ‘Light’ wines, which are lower in alcohol, can omit the reference product comparison, required Standard 1.2.7—16, provided the comparison is not a requirement of the importing market for such wines. | Light’ wines in this exemption only refers to lighter alcohol. Any other ‘light’ or ‘lighter’ claims, in relation to energy or nutrition content, does require a reference product comparison as well as a NIP on the label. |
| Energy statements | Standard 2.7.1—4A requires energy (kilojoule) content information to be included on the labelling of all alcoholic beverages. | Exported grape products do not need to be presented with the energy statement required by Standards 1.2.1—8(1)(za) and 2.7.1—4A unless it is a requirement of the importing country. | In many export markets, including energy-related information on a wine’s label may necessitate the provision of a comprehensive NIP. Separately, some markets require energy information to be communicated in a different format (e.g. the EU). Wine Australia therefore recommends that producers consider not including the Food Standards Code’s energy statement on products to be exported (other than to New Zealand). |
The Wine Australia Compliance Guide was last updated June 2026
Disclaimer
This Guide provides general information only and is not a substitute for legal or professional advice. It does not cover all licensing and compliance requirements and may not reflect the most recent legislative changes. Users should refer to the relevant legislation and seek independent advice where appropriate. Wine Australia disclaims all liability for any loss or damage arising from any reliance on this Guide. The information is current as at the date stated herein.