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The labelling of egg and milk when used as fining agents in wine is currently not covered by a permanent exemption from the allergen labelling requirements under Article 6 of Directive 2000/13/EC (as amended).
Egg and milk based wine fining agents have received several temporary exemptions from allergen labelling; the current exemption under Directive 2007/68/EC as last amended by Regulation No. 1266/2010 will come to an end on 30 June 2012. From that day onwards when egg or milk based fining agents have been used to make wine, they will need to be declared on the labelling unless proven to be absent in the final product.
The Commission has agreed the proposed amendments to Regulation (EC) No. 607/2009 which will lay down detailed rules for labelling wine. The agreed Regulation will require wine to be labelled when egg and milk fining agents used in the production of wine and are detected in the finished product using an appropriate method of detection. The method of analysis would need to be capable of determining absence (below 0.25mg/litre) of egg or milk protein in the wine for the purposes of deciding whether or not the product needs allergen labelling in accordance with Article 6 of Directive 2000/13/EC.
The requirement to indicate allergenic ingredients on label will apply to wines that have used egg or milk in their manufacturing process and have detectable levels of egg or milk protein present and were placed on the market or labelled after 30 June 2012. This includes imports.
Harvests in 2011 and earlier
Wine used as an ingredient in food
The exemption for allergen labelling for wine used as an ingredient in food would not be covered by the provisions of this Regulation. Therefore wine fined with egg or milk which is used in food would need to be declared on the labelling regardless of the level at which they are present.
The Regulation was published on Friday 29 June 2012 with the Commission issuing guidance on that day also. GRTU will provide another update once it has received further information from the Commission.
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