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This changes in tightened spirits legislation

Spirits legislation has been strengthened. There are changes in the legislation for the use of compound terms and allusions to spirits. This article lists the most important changes.

Earlier this year, the amended regulations for the labeling of blends were announced. The labeling requirements for spirits have been tightened in many areas as of May 25, 2021. Now changes for the use of compound terms and allusions to spirits will follow. The changes in legislation are necessary to ensure that consumers are adequately informed and not misled.

Spirits categories

Annex I of Regulation (EU) 2019/787 defines the requirements of different categories of spirit drinks. When a spirit drink meets the requirements of one of these categories, the name of that category must be used as the legal name, for example gin. The category name may also be supplemented or replaced by a geographical indication, such as "Tequila. In the case of liquor, the category name may be replaced by a compound term containing 'liqueur' or 'cream,' for example, cherry liqueur. When the spirit drink does not meet the requirements of any of the categories, the legal designation 'spirit drink' is used.

Using compound terms

Alcoholic beverages obtained by combining a spirit drink with other foodstuffs are described using compound terms. The compound term combines the category or geographical indication with the name of other foodstuffs. An example of such a compound term is "gin and tonic. The correct legal term for this beverage is 'spirits'.

In the same field of vision

The legal name of a spirit drink must now be compulsorily in the same field of vision as the compound term. Thus, on a bottle of "gin and tonic," the legal designation "spirit drink" will have to appear in the same field of vision as the compound term "gin and tonic. Indeed, if these entries are not in the same field of vision, 'gin and tonic' may be mistaken as the actual name of the drink. Thus the reputation of a category of spirits or a geographical indication is abused. This obligation does not apply to spirits where the legal name is replaced by a compound term that includes "liqueur" or "cream.

Allusions to spirits

An allusion is a direct or indirect reference to another legal designation in the labeling of a spirit drink, which is not a compound term or list of ingredients. The provisions regarding the use of allusions on spirits have recently been amended. According to these provisions, the use of allusions is permitted only for liqueurs. Allusions to other spirits are no longer allowed, to avoid overlap between allusions and mixtures of spirits. This is because a mixture refers to a combination of several categories of spirits. However, the legal designations for these categories are allowed on the label in the case of mixtures.
Example mixture:

  • Spirits
  • Mixture of Rum (60%) and Brandy (40%)

Traditional production methods

After consultation with the industry, it has become clear that the amended provisions make it impossible to properly inform consumers about certain traditional production methods when information relates to other spirits. In particular, this concerns the use of a spirit drink as the sole alcoholic base for processing into another spirit drink or the storage of a spirit drink in a cask that has previously contained another spirit drink. Therefore, allusions to spirits will again be allowed in the description, presentation and labeling of other spirits produced by these traditional methods. An example is when the label of a rum states that it was aged in a barrel that previously contained whiskey. Here, the allusions must be stated in a font size no larger and no more prominent than the font size of the legal designation.

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