The label The required words
What must every bottle of wine sold in Australia say?
A bottle of wine for retail sale in Australia carries a set of required statements. Most come from the Food Standards Code; the volume statement comes from the National Trade Measurement Regulations. This is the list, clause by clause, with the words that do the most work first.
General information about Australian wine labelling law. Each rule names its source; check the regulator’s page before you rely on it.
The required words
The words a bottle of wine for retail sale must carry, set by the Food Standards Code and trade measurement law.
The required words, compared
The Food Standards Code requires the label of a packaged food to carry the name of the food, a lot identification, the name and address of the supplier, and any advisory statements, warning statements and declarations it is subject to. For a food that contains alcohol it adds two statements: the alcohol content and the number of standard drinks.
Two general rules sit over all of them. A mandatory word, statement or design must be legible and prominent, contrasting distinctly with the label’s background, and any words must be in English. Wine Australia’s reading is that the Code prescribes no other print size, and that the general legibility rule is the one the statements stand on.
The Code also requires an energy statement for a prescribed beverage, which it defines as a standardised alcoholic beverage or a beverage containing no less than 0.5% alcohol by volume. The seven words in the table are the ones a bottle of wine usually carries, and they are the ones the home page’s required tier draws.
| Word | Required by | What it must say |
|---|---|---|
| Alcohol content | Standard 2.7.1, s 2.7.1-3 | A statement of the alcohol content, expressed in mL/100 g, mL/100 mL or as a percentage of alcohol by volume; for wine it must be accurate to within 1.5% alcohol by volume. |
| Standard drinks | Standard 2.7.1, s 2.7.1-4; Standard 1.2.1, s 1.2.1-8(1)(w) | The approximate number of standard drinks the package holds, to the first decimal place up to 10 drinks, and to the nearest whole number above 10. |
| Pregnancy warning | Standard 2.7.1, Division 4 | A pregnancy warning label on a prescribed alcoholic beverage: the pictogram for a small package, and the mark for a larger one. |
| Sulphites | Standard 1.2.3, s 1.2.3-4; Schedule 9 | A declaration that sulphites are present, where added sulphites reach 10 mg/kg or more. |
| Volume | The National Trade Measurement Regulations, as Wine Australia sets the rule out | The volume of wine in the package; on a standard 750 mL bottle the characters are at least 3.3 mm high. |
| Name and address | Standard 1.2.1, s 1.2.1-8(1)(c); Standard 1.2.2, s 1.2.2-4 | The name and business address, in Australia or New Zealand, of a person who is a supplier; a postal address will not do. |
| Lot identification | Standard 1.2.1, s 1.2.1-8(1)(b); Standard 1.2.2, s 1.2.2-3 | A lot code. Australia prescribes no format for it, and it is usually an alpha-numeric code. |
Alcohol and standard drinks
The alcohol statement is required for any food, alcoholic beverages included, containing more than 1.15% alcohol by volume, and it is written as so many millilitres of alcohol per 100 g or per 100 mL, or as the percentage of alcohol by volume. Its accuracy rule is where wine gets its own number: for wine and fruit wine, including sparkling forms, and for wine products containing more than 6.5% alcohol by volume, the statement must be accurate to within 1.5% alcohol by volume.
Standard drink, for a beverage containing alcohol, means the amount that contains 10 grams of ethanol when measured at 20°C.
Food Standards Code Standard 2.7.1, s 2.7.1-2, on the Federal Register of Legislation
The standard drink statement is required for a food that is capable of being consumed as a beverage and contains more than 0.5% alcohol by volume, measured at 20°C. It has to be accurate to the first decimal place for a food containing 10 or fewer standard drinks, and to the nearest whole number where there are more than 10.
Worked through on a bottle, using the calculation Wine Australia sets out: the volume of the container in litres, multiplied by the percentage of alcohol by volume, multiplied by 0.789, the specific gravity of ethanol, gives the number of standard drinks. A 750 mL bottle at 14% alcohol by volume works out at about 8.3, and Wine Australia’s example of the finished statement is “Contains approximately 8.3 standard drinks”.
Three more rules round out the alcohol picture. An alcoholic beverage that contains more than 1.15% alcohol by volume must not be represented as a low alcohol beverage. Wine and sparkling wine must contain no less than 45 mL/L of ethanol at 20°C, and wine must not contain added ethanol. And a food sold as wine has to be wine, as the Code defines it. The Code’s wine production standard applies to the production of wine in Australia only.
The pregnancy warning
A prescribed alcoholic beverage is one with more than 1.15% alcohol by volume that is for retail sale, or sold as suitable for retail sale without any further processing, packaging or labelling. One packaged in the presence of the purchaser is not one of them. A prescribed alcoholic beverage that has one layer of packaging must display a pregnancy warning label on its package; where there is more than one layer, the label goes on the outer package and on the individual units, unless the label on the units is clearly discernible through the outer package. FSANZ states the requirement plainly: packaged alcoholic beverages over 1.15% alcohol by volume for retail sale in Australia must display a pregnancy warning label.
There are two forms, and a bottle carries one or the other: the pictogram on its own, and the mark, which brings the pictogram together with the signal words and the statement, the three components inside a border. Here is the pictogram in the Code’s own words.
Pregnancy warning pictogram means the following pictogram with the silhouette of a pregnant woman holding a wine glass within a circle with a strikethrough.
Food Standards Code Standard 2.7.1, s 2.7.1-2, on the Federal Register of Legislation
The size rules follow the package. A prescribed alcoholic beverage of 200 mL or less carries the pictogram, at least 8 mm in diameter. One of more than 200 mL but not more than 800 mL carries the mark, whose pictogram is at least 6 mm in diameter. One of more than 800 mL also carries the mark, whose pictogram is at least 9 mm in diameter. On an outer package the mark’s pictogram is at least 11 mm in diameter, unless the package holds one unit of 200 mL or less.
The colours and the space around the mark are fixed as well. The background of the label is white, the circle and strikethrough of the pictogram are red, and the silhouette of the pregnant woman is black. The signal words of the mark are in red, and the border is black. It must be displayed as a whole and without modification, and Wine Australia’s reading is that the warning mark carries clear space of 3 mm around its border. FSANZ adds two practical notes: the colour of that clear space is not prescribed, and while its downloadable labels use PMS 485, other variations of red are permitted.
The requirement came in with a transition period. It was gazetted on 31 July 2020 with a three-year transition ending on 31 July 2023, and FSANZ describes the three years as the time businesses were given to implement it.
Sulphites
Sulphites are on the label because they are on the mandatory declaration list: added sulphites in concentrations of 10 mg/kg or more must be declared. The declaration is required where the substance is present as an ingredient, as an additive, or as a processing aid or a component of one.
Wine has its own wording, and a date for it. From 25 February 2024, the prescribed terms “sulphites”, “egg” and “milk”, as each applies, are the required names for wine and wine products, and wine is exempt from declaring isinglass derived from fish. Where more than one of the allergens is present, the declaration has to name all of them, in the form “Contains sulphites, egg and milk”.
One consequence of the way sulphites are made: yeast can produce them naturally during fermentation, so a “preservative free” claim is only open to a wine with no quantifiable level of sulphur dioxide in it. Below 10 mg/kg of naturally occurring sulphur dioxide, Wine Australia’s guidance says a label may be able to carry a claim such as “no added preservatives”.
Volume, name and address, lot
The volume statement has a minimum print size: on a standard 750 mL wine bottle, the characters are at least 3.3 mm high.
The supplier’s name and address is the name and business address in either Australia or New Zealand of a person who is a supplier. Wine Australia adds that the Australian business address must be on the label, and that postal addresses such as a PO box or an RSD number cannot be used.
Lot identification is the code that ties a bottle to a batch. Australia prescribes no format for it; Wine Australia says it is usually an alpha-numeric code, and that some markets, such as the European Union, require the code to start with the letter L.
Country of origin works differently for wine, and it is worth knowing how. Alcoholic beverages count as non-priority foods, so wine need not carry the mandatory standard marks, but it must state in text where it was grown, produced, made or packed. The Country of Origin Food Labelling Information Standard applies to non-priority food grown, produced or made in Australia, and a statement that the food was made in Australia satisfies the mark requirement. Wine Australia notes that the 85% rule for single-region claims does not apply to a country-of-origin statement, and that wording such as “Wine packaged in Australia from X% Australian and Y% [country] produce” meets both the domestic and the export requirements. For a wine made from grapes grown in more than one country, the Wine Australia Regulations require the label to identify the proportion that originated in each country, with grape-derived additives up to a total of 20 mL/L left out of that calculation.
Taken together, the label a person reads in a shop is answering to several instruments at once. Wine Australia puts it in one line: Australian wine labels answer to several different Commonwealth and State laws. The seven required words are the constant, and the guide on who checks the label follows the other set, the promises.