Label Requirements for Europe

[flyhigher87]

First off I am going to apologize now I’m not sure where this thread should go so you will probably see it published in a few locations that I think may apply.

Okay so I have a big order from a importer/distributor in Italy yay!!  However, I am trying to figure out the labeling requirements.  I asked the importer he said look at another company and do what they did.  (Thanks for all the help ?).  I looked it up on good ole’ google and I’m just finding some papers on self-regulation about possibly needing to list all ingredients on the label.  Looks like that is not required now.  

Does anyone know where I can find information on what the exact requirements are for the European Union?  The United States is very specific as we all know in our COLA approvals.  Does the EU have anything similar to this?  Do I need the get my label approved?  Please, help this order is the largest we’ve ever had for our tiny distillery.  I do not have the cash to make any mistakes.

 

Thank you all!

[paulNL]

First thing which you should read is EU regulation 110/2008 as it discribes what kind of spirits you can make and what name to put on them:

 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32008R0110

And after that look at regulation 1169/2011 for rules about labeling. Without a doubt there's some Italian website which condenses all this info and also tells you what (if any) symbols to add related to recycling of bottles, discouraging drink driving and consumption by pregnant women. This does vary by country, like the text that tells the ABV. And make sure there's a barcode on it that follows the rules, even many smaller liquor stores have scanners nowadays.

EDIT: forgot to mention COLA, we don't have something like that. You don't need to get your label approved. It should follow the rules.

Best regards,

Paul.

 

[flyhigher87]

Thank you very much Paul.  That was a big help!

[flyhigher87]

Paul I have been looking at the regulations and everything.  One question I see on maybe all the bottles I do not see in the regulations is for Volume I see  70 cl e.  I know 70 cl is 700 ml , but we is the e and do I need that?

[paulNL]

The "e" symbol tells the consumer that you've filled the bottle to almost exactly the amount as shown on the label. Without the "e" on the label there's a bigger margin allowed. And no, I don't have the "e" symbol on my labels, like most smaller producers of spirits and wines. Not a single consumer or shop has refused my bottles because of this. I've discussed this with a botteling plant, even though they can fill bottles to the "e" specification they said I can leave the "e" off just so I can use the same label design on everything I bottle myself.

I don't know the exact margins allowed off the top of my head, but if you can't find it I'll try to help you.

[paulNL]

More info in fill levels in the EU: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A31975L0107

[dhdunbar]

TTB has a division that can help you understand what is needed to export product to different countries.  Here is a start for Italy;

https://ttb.gov/itd/italy.shtml

Here is the contact information for the division;

For more information contact IAD online, by phone at 202-453-2260, or by fax at 202-453-2970. 

Please direct correspondence to:

Alcohol and Tobacco Tax and Trade Bureau
Director, International Affairs Division
1310 G Street, NW, Box 12 
Washington, DC 20005

 

 

 

[meerkat]

I hope that someone can confirm that this is irrelevant, but I wouldn't want you to be blindsided by something you could have been aware of.  In the EU everything is measured at 20°C rather than the 60°F used by the TTB.

This means that while 80.00 proof converts to 40.00% ABV at 60°F it would be 40.07% ABV at 20°C.  This is because alcohol expands more with temperature than water does.

I see from the regulations linked by Paul that you would have a volume tolerance of 10 ml on a 750 ml bottle.  The volume of 750 ml of 80.00 proof spirit at 60°F would increase by 2.3 ml at 20°C, so this should not be a problem if you plan for it.

[flyhigher87]

You guys are awesome thank you so much.  Anyone know about warning labels I see everyone has the pregnant lady drinking with an X through it and a recycle sign.  I’’ve seen a few with a anti-drinking and driving symbol but more than most do not have that symbol? And I have not seen any regulations on what is required.   Sorry for all the questions i’m Super nervous my pallets of bottles will get there and they say the label is not Correct and then they throw my bottles in the Ocean(Its a reacurring nightmare).

[paulNL]

Symbols for recycling, drink/driving and pregnancy are not a part of the European laws as specified in EU regulation 110/2008. Every country MAY introduce laws or guidelines regarding these symbols themselves, and most have done so. Example: in the Netherlands most of the big distillers are a member of the trade organisation SpiritsNL, and they ask their members to use these symbols. I'm not a member myself (and therefor not required to use them), but I do.