Wine Australia audits are on the rise. Some tips.

According to the most recent Wine Australia Operational Plan the number of Australian Wineries targeted for audit has increased by 33% to 400 in 2013-2014. That’s about a 1 in 4 chance of getting audited on your Label Integrity compliance. The auditors can cold-call or make an arranged visit, so how confident are you that your record keeping would comply?

The quicker you can satisfy an auditor, the quicker you can send them to the cellar door to pick up some purchases for the trip home. Don’t get us wrong, the Wine Australia people are lovely folks, but I’m sure you’d rather be selling or making more wine rather than pouring over blend history log books and weigh tags. Are your systems efficient enough to give the auditor what they need when they come knocking?

In addition to receipt and supply, wine producers need to record specific details about wine movements and changes in composition that may affect the label claim in any way. The requirements are precise and all detailed in the Wine Australia Corporation Act, Section 39F.

The Label Integrity Program (LIP)

While you’re not required to make a label claim on your wines, those that do, need to ensure you have the audit trail to back that claim up. A label claim is a written statement on a wine label, commercial documents, advertisements or records that claim or imply a wine is from a particular vintage, variety and GI.

In addition to receipt and supply, wine producers need to record specific details about wine movements and changes in composition that may affect the label claim in any way. The requirements are precise and all detailed in the Wine Australia Corporation Act, Section 39F.

Under the Label Integrity Program (LIP) you need to keep records on all ‘wine goods’ including wine, grapes or grape extracts intended for use in wine production. It’s also mandatory to keep records of who you received these goods from and who they were supplied to under the ‘One step back’ and ‘One step forward’ requirements. When buying or selling wine goods, you need to make sure you supply or receive a Wine Goods Supply Statement with key information including: date, supplier and customer, quantity as well as vintage, variety and GI composition.

Did you know? Wine Australia is considering introducing penalties for minor infringements.

In addition to receipt and supply, wine producers need to record specific details about wine movements and changes in composition that may affect the label claim in any way. The requirements are precise and all detailed in the Wine Australia Corporation Act, Section 39F.

  • The identity of the record keeper;
  • The kind of wine goods to which the record relates;
  • The date the record keeper receives the wine goods;
  • The identity of the person from whom the wine goods are received;
  • The quantity of the wine goods received;
  • The vintage, variety and geographical indication of the wine goods;
  • Details of steps taken by the record keeper that changed or affected any of the following:
  • The vintage, variety or geographical indication of the wine goods;
  • The tank or other storage unit in which the wine goods were stored;
  • The volume of the wine goods stored in the tank or storage unit;
  • The date the record keeper supplies the wine goods;
  • The identity of the person to whom the wine goods are supplied;
  • The quantity of the wine goods that are supplied;
  • The vintage, variety and geographical indication of the wine goods;
  • Any other details in relation to the wine goods that are prescribed by the regulations

Did you know? Records must be made within 3 days and kept up to 7 years.

As well as complying with the record keeping requirements you need to adhere to the blending rules which prescribe the thresholds for claiming multiple versus single variety, vintage, GI. Here is a handy table that will help explain the rules:

LIP Table

*Each variety named in the description and presentation must be present in greater proportion in the composition of the wine than any variety that is not named
**A maximum of three GI’s can be claimed
Table sourced from the Wine Australia Compliance Guide 2014 and subject to change by Wine Australia.

Don’t forget about the Food Standards Code.

You need to track wine additions and processing aids to comply with the Australia and New Zealand Food Standards Code. The topic of which is outside of the scope of this particular article but it does add another level of record keeping and tracking. Like being able to identify the presence of allergens over time has been added to a batch of wines through various blends and movements.

Practical tips to stay compliant and survive an audit

  • Nominate a primary record keeper. If you want a more official sounding title call them the “Compliance Officer”
  • Ensure you plan your working week to allow time for record keeping
  • Regularly check the last recorded entry to ensure you are recording winery work within the 3 day requirement
  • If using spreadsheets, remember that you need to keep records for 7 years so make sure you are regularly backing up your files
  • Consider running a separate log book or file for each vintage year
  • Use the free Wine Australia LIP templates available for download here
  • Or consider a wine production software system that helps manage this for you

Factors to consider when evaluating software systems

  • How easy is the software to use? Can you get a free demo to see for yourself?
  • Do I need to buy a new computer to run it or is it Cloud based?
  • Is your data secure and regularly backed up?
  • Can it generate compliance documents such as the Wine Goods Supply Statement?
  • Does it work on an iPad, iPhone or other smartphone?
  • What value adds does it offer? Things like harvest scheduling, lab management, barrel barcoding, Cost of Goods tracking etc
  • Is it a capital purchase or can you pay by the month?
  • What do other customers say about it? Make sure you get some references.

Where can I find more information? Wine Australia have a terrific compliance guide available on their website as well as details about their compliance activities in the yearly Operational Plan. We’d encourage you to read both and if unsure of anything contact Wine Australia direct for advice.

Disclaimer: This article is intended as general information and should not be taken as legal advice. Information has been sourced from the 2013-2014 Wine Australia Operational Plan and the Wine Australia Compliance Guide 2014.

Joshua Abra

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