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Federazione italiana industriali produttori esportatori ed importatori di vini, acquaviti, liquori, sciroppi, aceti ed affini

FEDERVINI

FEDERVINI è stata fondata nel 1917 e i suoi membri sono imprenditori in diversi settori delle bevande alcoliche (vini, aperitivi, amari, liquori e distillati) aceti, sciroppi e succhi.

Lobbying Activity

Response to Indication of wine ingredients and adaptation of the rules for geographical indications in the wine sector

21 Feb 2023

As a first general comment, considering that it is fundamental to have legal certainty and allow business operators to anticipate the application of the new labelling requirements for the mandatory communication of the list of ingredients for wines and aromatised wine products, FEDERVINI strongly asks for the European Commission to adopt and publish the Delegated Act without delay. On the content of the draft regulation, we welcome the proposed rule of using the term grapes to indicate the raw material, used for the production of the wine, since grapevine products are always produced from grapes. We support the proposed simplification rule on concentrated grape must term independently of the form used (concentrated or rectified-concentrated). In fact, to facilitate the understanding of consumers and the management of wine list of ingredients, the term concentrated grape must may be used independently if the winemakers decides to use the concentrated grape must under other forms (concentrated or rectified-concentrated). FEDERVINI welcomes the Commissions proposal ruling the possibility to present the additives causing allergies or intolerances, by using the generic terms sulphites, egg, milk set in Annex I - Part A, in the meaning of the Article 41 of Commission Delegated Regulation (EU) 2019/33. Furthermore, we welcome the fact that the Commissions rule applies irrespective of if the list of ingredients is given on label or off-label. We consider that for the designation of additives, alongside the use of terms set in column 1 of Table 2 of Regulation (EU) 2019/924, the use of E-numbers or other official terms for certain additives should be authorised. We welcome the Commissions proposal ruling the possibility to replace the components of the expedition liqueur by the term expedition liqueur alone or followed in brackets by the list of constituents, left to the producer/bottler appreciation. FEDERVINI welcomes the Commissions proposal ruling the possibility to replace the components of the tirage liqueur by the term tirage liqueur alone or followed in brackets by the list of constituents, left to the producer/bottler appreciation. Finally, a last comment on the exhaustion clause. Article 5.8 of Regulation (EU) 2021/2117 states that wine products produced and labelled before 8 December 2023 may continue to be placed on the market without indicating the list of ingredients and the nutrition declaration. The strict application of this rule raises serious concerns for wines produced before that date and that are aging (barrels and bottles). This is the case of base wines already produced and used notably for the production of sparkling wines (including through tirage and expedition liqueurs) or for blending of still wines and for the production of aged wines which will be released for consumption after 8 December 2023. In light of the above, for greater legal certainty, FEDERVINI strongly asks the European Commission to allow exemptions for all wines produced before 8 December 2023.
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Meeting with Elina Melngaile (Cabinet of Executive Vice-President Valdis Dombrovskis), Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis) and

23 Jun 2021 · EU-US trade relations; Trade relations with other third countries