Labelling (Regulation 1169/2011)

Along with all other foodstuffs, spirit drinks provide label information to inform consumers and help them make meaningful choices.  The rules are laid down in EU laws and these are often supplemented by national rules requiring further details or stipulating the language in which mandatory information must be shown.

At its most basic level, the labels of all spirits in the EU must show the following: sales designation; alcoholic strength; net contents; producers / trader contact details; any allergens that are present; and the batch or 'lot' code.  At national level, some Member States have additional requirements, sometimes as a consequence of legislation and sometimes through agreements with industry (the so-called mandatory -voluntary approach).  The requirements can include provision for labels to show elements such as: logos to warn pregnant women not to drink; responsible drinking messages; information on the presence of particular colorants.  

Elsewhere there are further, invariably contractual requirements, such as the 'green dot' which is used in many countries. Contrary to popular belief, this does not denote that a product is "green" or that the packaging is environmentally friendly; rather it denotes that the organisation which put the product on the market is a member of the national packaging waste recovery scheme.  These aim to ensure that, at the end of its lifespan, packaging is recovered so it can be recycled or disposed of in an environmentally friendly manner.  

For many years it has been accepted that, while fully a part of the foodstuff sector, alcoholic beverages require a marginally different treatment to other sectors.  Rules are currently being discussed on whether, and if so how,  beer, wine and spirits should label their ingredients and / or declare nutrition information.  For our sector the issue is simple: we have nothing to hide. But we do need any new labelling requirements to be both meaningful to consumers and applied equally to all sectors.  Beer, wine and spirits all contain exactly the same alcohol compound (ethanol) so the labelling rules should treat each sector the same way.

In the case of ingredients, the distillation process transforms the raw materials so that they are no longer present in the final product.  Thus there are no grapes in brandy, no molasses in rum and no cereals in whisky.  This being the case, the main ingredient of these spirits would be, respectively, brandy, rum and whisky.  Water would be a further ingredient, as would the tiny quantities of caramel that are sometimes added to harmonise colour between batches.  

With regard to nutrition, the distillation process means that, for most categories of spirit, none of the normal nutrients are found.  Thus a vodka, whisky or rum would not contain any fat, carbohydrate, sugar, protein or salt.  All spirits, and indeed all beers and wines, are alcoholic beverages and contain energy derived mainly from their common element, ethanol.  Our sector has long indicated its willingness to declare the energy content of spirits. Many are already doing so through their websites.  Critically, it will be vital to ensure that energy declarations are meaningful and do not mislead consumers.  

While EU foodstuffs are required to declare energy per 100g or 100ml, this would be wholly inappropriate for alcoholic beverages and would mislead consumers.  Beer is always sold in quantities larger than 100ml; spirits are always sold in quantities less than 100ml.  A comparison by 100ml would result in beer appearing to be the least calorific alcoholic beverage when it is actually the most calorific. Spirits would appear to be the highest when in fact most are the least calorific beverages.  A requirement to declare energy per 100ml would thus present consumers with highly misleading information as showed below:

Instead of a declaration per 100ml, we believe it should be on the basis of comparable quantities, that consumers will recognise, and therefore allow them to make meaningful comparisons and control their calorie intake.