Whilst the Export Market Grid is being updated, the following information on Chinese labelling requirements has been made available to assist exporters to China.

The two most critical pieces of legislation are the wine standard (GB 15037) and the wine labelling law (GB 10344) both of which are administered by the General Administration of Quality Supervision, Inspection and Quarantine of the People's Republic of China. The following information is taken from the 2005 versions of both documents, which are believed to be current. Furthermore, the wine labelling law is a specific application of the General standard of pre-packaged food labelling, GB7718, of which the 2004 version is believed to be current.

Given the difficulties associated with translation and interpretation, not to mention the reputation of Chinese regulatory authorities for inconsistent application of the rules, it is recommended that the following information be treated cautiously. Your importer or agent should be consulted for further details. Enquiries on China can be directed to the Compliance Centre.

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(1) Minimum Durability Date only applies to wines with an alcohol content of 10% or less.

A1        Name of Product

The name of the product is mandatory in China. The words "grape wine" should be sufficient, however it is advisable to qualify this with "red", "white", "sparkling", ‘semi-sparkling, "fortified", "sweetened fortified" etc. For definitions of these categories please see A9.

A2        Ingredient List

As wine can be considered to be made from a single raw material it should be exempt from the requirement for ingredient listing. Nevertheless, sweeteners, preservatives and added colour (legal in the case of fortified wine only) need to be declared. The name of the substance (sulphur dioxide, sorbic acid, caramel etc) should be declared rather than the generic category, for example, "preservative" or "colour". Added acids should also be declared.

A3        Alcohol Statement

The alcohol format is prescribed in Chinese regulations. The alcohol statement should be in the form "Alcoholic strength xx.x% vol". (Apparently % Mass is also acceptable and this may account for some of the reported disparity between results obtained from testing authorities within China).

The tolerance between the actual and the stated alcohol is +/- 1.0% in China.

A4        Volume Statement

The volume statement must appear on the label. The statement must be on the same display panel as the word "wine". This should be marked as "net content xxx Ml (ml)" for bottle sizes under a litre, or "net content x Litres (l)" for bottle sizes over a litre. For packages up to and including 200ml the minimum print height is 3mm. From 200ml up to and including 1 litre the minimum print height is 4mm. For packages greater than 1 litre the minimum print height is 6mm.

A5        Name and Address

The name and address of the Chinese agent, importer or distributor must be shown on the label. The name and address of the producer is not mandatory, however if included does not need to be translated into Chinese characters.

A6        Country of Origin

A country of origin statement is mandatory. Importers will usually request a Certificate of Origin to confirm this claim. Certificates of Origin can be obtained by state Chambers of Commerce.

A7        Bottling Date

The date of bottling is required on Chinese labels. If for instance, the product is bottled on Australia day 2006 the following would be acceptable.

2006 01 26, or 20060126, or 2006-01-26, or Jan. 26th 2006.

Compliance with this requirement could be extremely difficult as the standard Australian batch or lot labelling using the Julian date code does not appear to be acceptable to the Chinese. Neither can the bottling date be applied in the form of a sticker, reprint or tampering which suggests that the label itself must contain the required information. We suggest that negotiation with your bottler is required in order to satisfy this traceability requirement.

A8        Minimum Durability Date

Wines with an alcohol content of 10% or less are required to include a minimum durability date. Wines over 10% alcohol are exempt from this requirement (GB7718-5.2.1 and GB10344-5.2). Nevertheless many importers and/or regulatory authorities seem unaware of this exemption and it is advisable to include a statement such as "recommended to drink before (year)".

A9        Product Type

The product type is mandatory for China. This can be indicated by the actual sugar content or by the category. The following categories apply;

A9.1 Still Wines

A9.2 Fortified Wine

Fortified wine is defined as being produced from must with an initial total (ie, actual + potential) alcohol content of at least 12%. Fortification cannot be before the original wine reaches at least 4% alcohol. If concentrate is added the product must be designated "sweetened fortified wine".

A9.3 Sparkling Wine

Note 1 bar = 0.1 Mpa. Sparkling wines are defined as wines with a carbon dioxide pressure at least 0.35 Mpa at 20'C. The carbon dioxide must all be derived from fermentation. The requirement is relaxed to 0.30 Mpa in the case of bottles smaller than 250mL. The following type designations apply;

A9.4 Semi-Sparkling Wine

Semi-sparkling wines are defined as wines with a carbon dioxide pressure between 0.05 and 0.34 Mpa at 20'C. The carbon dioxide must be derived from fermentation. The sweetness categories are as per still wines.

A9.5 Carbonated Wine

Carbonated wines are defined as wines in which all or some of the carbon dioxide has been added.

A10      Vintage, Variety and Geographical Indication

Vintage, variety and Geographical Indication claims are optional; however, if they are claimed Australian blending regulations apply.

A11      Prohibited Items - European Regions

Geographical regions of the European Union cannot appear on Australian labels regardless of the context in which they may be used. For a list of European regions refer to the list in the EU Australia Wine Agreement.

The AWBC does not accept responsibility for the results of any actions taken on the basis of the information contained in this guide, nor for the accuracy, currency or completeness of any material contained in it.

The AWBC expressly disclaim all and any liability and responsibility to any person in respect of the consequences of anything done in respect of reliance, whether wholly or in part, upon this document.