2- From a tax point of view :
2.1- Distance selling of alcoholic beverages
2.2- Excise duties via local tax representative
2.3- Calculate excise duties to pay in destination / to claim in your own country
2.4- Drawback/refund of excise duties
2.5 – INTRASTAT
3- Alcohol online market
3.1- Circulation of cross-border orders
3.2- Labelling cross-border orders (ingredients)
3.3- Labelling alcohol with destination duty stamps
3.4- Contractual duties of e-retailers and Consumer’s rights
3.6- Packaging wastes compliance
1. Legal framework of labeling
In force: Regulation (EU) 1169/2011 (EU 2011).
First, a European Commission report on mandatory labeling did list the ingredients and nutrition declaration of alcoholic beverages (EC 2017). This acknowledges the progress made by the industry sector in the provision of consumer information on a voluntary basis. It invited the industry to present ‘a self-regulatory proposal that would cover the entire sector of alcoholic beverages’. The European alcoholic beverages sector did submit a joint self-regulatory proposal (EC 2018a) together with sector-specific annexes (ECa). This is under current assessment by the Commission. If found unsatisfactory, the Commission can launch an impact assessment to review other options available. This option will include regulatory and non-regulatory options.
1.1 Labeling alcoholic beverages
Second, the provision of food information to consumers has a requirement that the ‘actual alcoholic strength by volume’ of an alcoholic beverage that has more than 1.2 % by volume of alcohol should be given. The figure should give no more than one decimal place. Also, the symbol ‘% vol’ will follow. The word ‘alcohol’ or the abbreviation ‘alc’ can precede it. Alcoholic beverages with more than 1.2 % abv are exempt by the same regulation to show any nutrition declaration. This includes any mandatory list of ingredients too.
1.2 Labeling allergens
The presence of specific compounds, such as frequent allergens (e.g., sulphur dioxide/sulphites, egg and milk products in the case of wine), and glycyrrhizinic acid or its ammonium salt should be added as part of the list of ingredients, or in the absence of such, accompany the name of the beverage. The regulation does state that it is not mandatory to indicate a date of minimum durability in the case of beverages that contain more than 10 % abv.
1.3 Exemptions when labeling
No alcoholic beverage that has more than 1.2 % abv can bear any health claims of any kind in the EU. Thus, only claims that refer to low alcohol levels, the reduction of the alcohol content, or the reduction of the energy content for these beverages are permitted (EC 2006a) for nutrition claims.
2. National compliance on labeling
Finally, EU labeling is just one requirement that can affect member states. However, member states can adopt national measures on labeling as well. This is subject to a specific notification procedure and positive assessment of the European Commission. For example, in France and Lithuania, labels of alcoholic beverages require a warning that alert consumers about the potential health consequences of alcohol exposed pregnancies. A pictogram or text provide the necessary information for the consumer (Legifrance 2006).
More topics on compliance :
Contact us and get a quotation