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Distilled spirits are as diverse as the EU, spanning 46 product categories and including over 240 spirits with geographical indications, all of which are an integral part of the culture of their regions. As the critical origin element for spirit drinks is the place where the process and know-how confers the quality, and thus reputation, of the spirit drink, it is not infrequent for producers to indicate origin. The implementation of new rules for voluntary origin labelling under article 26.3 will therefore have an impact on an important number of products.
When determining policy on origin, spiritsEUROPE calls on regulators to consider the specificity of the spirit drink sector and, in particular, the provisions of Regulation 110/2008. EU rules defining spirits date back to 1989, with national provisions often much earlier. These define and protect the traditional production practice on which the global reputation of EU spirits is based, ensure fair competition between producers and proper protection for consumers.
In almost all cases, the origin of ingredients and/or raw materials is not of defining importance. Rather it is the know-how, method of production and territorial link that is crucial; hence in 110/2008, a very specific concept of ‘place of manufacture’ is applied, as follows: “… means the place or region where the stage in the production process of the finished product which conferred on the spirit drink its character and essential definitive qualities took place”. This specificity needs to be reflected in the new origin labelling rules, in particular that all spirits with geographical indications should be automatically excluded from the new rules, i.e. exactly the same way as the draft treats other foodstuffs with geographical names.
More specifically, we consider that only the origin of the ingredient, and not the raw material, is relevant in this context. It is also important that water used for the dilution of spirits should be excluded from consideration. At a more administrative level, we hope guidelines on the interpretation of the new rules can be drawn up at European level in parallel and that a transition period of at least 3 years should be given to allow companies to adjust to the new rules.
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