Wine Label Compliance in Australia: A Trade Customer's Reference Guide
Wine label compliance in Australia is governed by multiple regulatory frameworks that change periodically. For sign shops, design studios, and trade resellers fulfilling wine label orders for winery clients, getting the compliance check right at the artwork stage saves the winery client from expensive reprints and potential regulatory consequences after release.
This guide is the trade customer's general reference for recognising obvious compliance issues on incoming wine label artwork. It is not legal or regulatory advice. The compliance decisions on any specific wine label belong to the winery client and their regulatory advisors — not to Mediapoint, and not to the trade customer fulfilling the order. What this article gives you is the framework to recognise when a wine label artwork is obviously missing required elements, so the conversation with the client happens before the file enters production rather than after the labels are printed.
Critical responsibility disclaimer — please read carefully:
The information in this article is general reference material based on Mediapoint's experience as a trade label printer and publicly available regulatory information current at the time of publishing. It is not legal advice, regulatory advice, or a substitute for consulting Food Standards Australia New Zealand (FSANZ), Wine Australia, or a qualified regulatory advisor on specific compliance questions.
Mediapoint does not provide compliance advice, does not verify the regulatory compliance of supplied artwork, and accepts no responsibility for the regulatory compliance of any wine label produced. Mediapoint prints supplied artwork as a trade service. The winery client (or the trade customer acting on their behalf) is solely responsible for ensuring artwork meets all applicable regulatory requirements before submission to print, including but not limited to FSANZ standards, Wine Australia requirements, the Australia New Zealand Food Standards Code, the Country of Origin Food Labelling Information Standard, the Wine Australia Act 2013 and Wine Australia Regulations 2018, and any export market regulatory requirements.
Regulatory frameworks change periodically. The information in this article reflects general guidance current at the time of publishing and may not reflect subsequent regulatory updates. For current authoritative requirements, consult FSANZ directly at foodstandards.gov.au and Wine Australia at wineaustralia.com.
Who's responsible for what
A clear picture of compliance responsibility helps trade customers position client conversations correctly.
The winery client (or wine producer) is responsible for:
- Determining what regulatory requirements apply to their specific wine product
- Engaging qualified regulatory advisors for compliance decisions
- Ensuring artwork meets all applicable regulatory requirements before approval
- Maintaining Label Integrity Program records as required for vintage, variety, and origin claims
- All consequences of non-compliant labelling reaching market
The trade customer (design studio, sign shop, or reseller) is responsible for:
- Receiving, processing, and submitting client artwork accurately
- Recognising obvious compliance issues on incoming artwork and raising them with the client before submission
- Communicating client requirements correctly to Mediapoint
Mediapoint is responsible for:
- Printing supplied artwork to the technical specifications agreed at order time
- Producing labels that match the supplied artwork file accurately
Mediapoint is NOT responsible for:
- The regulatory compliance of supplied artwork
- Verifying that artwork meets FSANZ, Wine Australia, or any other regulatory requirements
- Compliance advice, regulatory advice, or legal advice on wine label content
- The consequences of compliant or non-compliant labels in the market
This responsibility framework means the trade customer plays a useful intermediate role: not making compliance decisions (that's the winery's job), but flagging obviously non-compliant artwork before the file enters production. The two-minute conversation upfront when something looks wrong saves the winery client from the much larger cost of discovering the issue after production.
What appears on a compliant Australian wine label
The general elements that must appear on Australian wine labels under current FSANZ standards and Australian Consumer Law. Each element below is followed by general guidance only — for specific decisions about any wine label, the winery client must consult FSANZ, Wine Australia, or qualified regulatory advisors.
Pregnancy warning mark
Mandatory on all packaged alcoholic beverages exceeding 1.15% alcohol by volume. The pregnancy warning mark has a specific prescribed format:
- A pictogram (silhouette logo) in black and red
- The signal words "PREGNANCY WARNING" capitalised, in red, bold, sans serif font
- The statement "Alcohol can cause lifelong harm to your baby" in black, sans serif, sentence case
- All three components contained within a black border on a white background
- 3mm clear space surrounding the border
The size requirements vary based on the container type (bottle, can, cask) and total beverage volume. FSANZ publishes downloadable pregnancy warning label files in the prescribed format — the winery client should source the correct version from FSANZ rather than recreating the mark in design.
This is the single most commonly missed or incorrectly formatted element on incoming wine label artwork. If you receive client artwork without a pregnancy warning mark — or with one that's been redrawn rather than using the FSANZ-supplied file — raise it with the client immediately. The compliance failure can require a full reprint at the winery's expense.
Allergen declarations (mandatory wording since 25 February 2024)
Wine labels must declare specified allergens if present in the wine or used in its manufacture. Since 25 February 2024, the prescribed terms must be used:
- "sulphites" (not "sulfites" or "contains sulfites")
- "egg" (if egg products used in fining)
- "milk" (if milk products used in fining)
The prescribed wording must be plain English. The legal requirement is that the statement must say either that the substance is in the wine or that it has been used in its manufacture. Where multiple allergens are present, the declaration must include all of them (for example, "Contains sulphites, egg and milk").
Wine is exempt from the requirement to declare isinglass derived from fish.
Common compliance failure: wine labels still using older wording ("contains sulfites" with the "f" spelling instead of "sulphites" with the "ph" spelling). Stock labelled before 25 February 2024 with older wording could be sold until 25 February 2026 — but new label artwork must use the current prescribed plain English terms.
Alcohol content statement
Mandatory for all alcoholic beverages containing 0.5% or more alcohol by volume.
For wine containing more than 1.15% alcohol by volume: expressed as a percentage of alcohol by volume (for example, "13.5% alc/vol"). The statement must be accurate within 1.5% alc/vol for wine, sparkling wine, and wine products containing more than 6.5% alc/vol.
For wine containing between 0.5% and 1.15% alcohol by volume: expressed in words to the effect of "contains not more than X% alcohol by volume."
Wine containing more than 1.15% alcohol by volume must not be represented as a "low alcohol" beverage or words to similar effect.
Standard drinks declaration
Mandatory on all packaged alcoholic beverages. Indicates the approximate number of standard drinks in the container. Calculated from alcohol percentage and container volume. Wineries typically have software, templates, or service providers that handle this calculation accurately.
Country of origin statement
Mandatory under the Country of Origin Food Labelling Information Standard 2016. Wine is classified as a "non-priority food" under this standard, which means it's exempt from the mandatory standard marks (the kangaroo logo and bar charts seen on packaged groceries), but must include a text statement indicating where the wine was grown, produced, made, or packed.
Wine producers should understand the distinctions between "grown in," "produced in," "made in," and "packed in" when making origin claims. The Australian Competition and Consumer Commission (ACCC) provides detailed definitions and examples for guidance.
Imported wines must also carry a country-of-origin statement. If grapes, juice, or wine from multiple countries are included, all countries of origin must be listed.
Producer or supplier name and address
The name and address of the producer, packer, or supplier must appear on the label. This is typically the winery's registered business name and street address (a PO Box address alone is not sufficient — the address must be a physical location). The full name and address allows traceability for regulatory purposes and consumer enquiries.
Lot or batch identifier
Mandatory under the Food Standards Code. Lot identification serves traceability purposes in the event of a product recall or withdrawal. Without lot identification, all product carrying the same label may be compulsorily recalled rather than just the affected production run.
For Australia, no specific format is prescribed — typically an alphanumeric code, sometimes following a day/month/year pattern. Some markets (such as the European Union) require the lot code to commence with the letter "L." The lot identifier may be placed anywhere on the label that will be visible after finished packaging, and is often stamped on the bottle at the time of bottling rather than printed on the label itself.
If the wine is a single product from a single batch, the label itself can serve as the lot identifier.
Net contents (volume statement)
Mandatory. Expressed in millilitres (mL) or litres (L) — for example, "750mL". The volume statement must be accurate within the tolerances specified by trade measurement legislation.
What's coming — mandatory energy statements from August 2028
A significant compliance change is on the horizon that trade customers and winery clients should be planning for now.
The Food Standards Code was amended on 13 August 2025 to require energy statements on most packaged alcoholic beverages, including wine. There is a three-year transition period: products packaged and labelled on or after 13 August 2028 must include an energy statement on their label.
The energy statement must appear in a prescribed tabular format with borders. The statement must clearly indicate that the quantities shown are average quantities (this could be indicated in column headings).
FSANZ has released an online calculator to assist with energy content calculations and published guidance to help businesses prepare for the implementation date. Trade customers should be aware that winery clients designing new labels for use after August 2028 need to incorporate the energy statement into the design — leaving space for the tabular energy panel at the artwork stage is much easier than retrofitting it later.
For trade customers: when discussing new wine label projects with winery clients, mention the upcoming energy statement requirement. Clients designing labels intended for use beyond August 2028 should consider:
- Allocating space on the label artwork for the energy statement panel
- Consulting with their regulatory advisor on energy content calculation
- Sourcing the prescribed energy statement format from FSANZ guidance
- Building the energy statement into new artwork rather than treating it as an afterthought
This isn't a compliance requirement Mediapoint needs to enforce — but flagging it with clients in 2026 and 2027 is the kind of value-add that distinguishes a thoughtful trade customer from one who just processes orders.
Vintage, variety, and origin claims — the Label Integrity Program
If a wine label makes claims about vintage (e.g., "2024"), variety (e.g., "Shiraz" or "Chardonnay"), or origin (e.g., "Barossa Valley" or "Margaret River"), the winery must comply with the Label Integrity Program (LIP) administered by Wine Australia.
The Label Integrity Program is a self-funded industry control system that requires winemakers to maintain detailed records substantiating any vintage, variety, and origin claims. Wine Australia conducts audits to verify these claims against the records. Non-compliance can result in regulatory action.
For trade customers: you don't need to verify whether a vintage, variety, or origin claim is substantiated — that's the winery's responsibility under LIP. But you should recognise that any vintage year, varietal name, or geographic indication on incoming artwork is a regulated claim that the winery must be able to defend if audited.
Geographic Indications (GIs) — particular care required
Australian wine geographic indications (Barossa, Coonawarra, Hunter Valley, McLaren Vale, Margaret River, Tasmania, and others) are protected designations. Wine labels using a GI must comply with strict rules about the percentage of grapes from the indicated region (typically 85% minimum for the named GI).
Some markets (including the European Union, the United Kingdom, and the United States) recognise Australian GIs through international agreements. Wines labelled for export to these markets have additional GI compliance considerations.
For trade customers: if incoming artwork uses an Australian regional name (Barossa Valley, McLaren Vale, etc.), that's a protected GI claim — the winery client must have the records to substantiate it. This is the winery's compliance burden, not the trade customer's, but worth noting that GI claims are subject to formal scrutiny.
Common compliance issues on incoming wine label artwork
The recurring issues Mediapoint's prepress team sees on incoming wine label artwork that trade customers should recognise. None of these issues are Mediapoint's responsibility to fix — they're the client's compliance issues to address before submitting the file. The role of the trade customer is to flag the issue early so it gets resolved before production.
Pregnancy warning mark missing entirely
Watch for: wine label artwork with no pregnancy warning mark anywhere on the design. Consequence: legally non-compliant label. Action: raise with client immediately and request revised artwork with the FSANZ-supplied pregnancy warning mark included.
Pregnancy warning mark redrawn or modified
Watch for: pregnancy warning that appears to be a recreation rather than the FSANZ-supplied file — wrong proportions, modified text wording, altered colours, missing the 3mm clear space, etc. Consequence: non-compliant warning mark. Action: request the client source the FSANZ-supplied pregnancy warning file and use it as-supplied.
Old "contains sulfites" wording instead of "sulphites"
Watch for: allergen declaration using older spelling. Consequence: non-compliant for labels produced after 25 February 2024. Action: flag with client to update wording to current prescribed plain English term "sulphites."
Missing allergen declaration
Watch for: artwork with no allergen statement at all. Consequence: non-compliant if the wine contains regulated allergens. Action: confirm with client whether the wine contains sulphites, egg products, or milk products from fining or production — if yes, declaration must appear on label.
Alcohol content statement missing or inaccurately positioned
Watch for: artwork with no alcohol percentage statement, or with the alcohol percentage in unusually small or hard-to-read positioning. Consequence: non-compliant. Action: confirm with client that the alcohol content statement is present and clearly legible at the printed size.
Country of origin statement missing
Watch for: artwork with no statement indicating where the wine was grown/produced/made/packed. Consequence: non-compliant under Country of Origin Food Labelling Information Standard 2016. Action: request client confirm the appropriate origin claim and ensure it appears on the label.
Standard drinks declaration missing
Watch for: artwork without an indication of the approximate number of standard drinks. Consequence: non-compliant. Action: flag for client to add.
Producer name and address missing or PO Box only
Watch for: producer name without a physical address, or with a PO Box address only. Consequence: non-compliant. Action: confirm with client that a physical street address appears alongside the producer name.
Critical compliance text positioned within 3mm of the trim edge
Watch for: pregnancy warning, allergen declaration, alcohol percentage, or standard drinks statement positioned close to the cut line. Consequence: production trim drift may clip critical compliance content. Action: confirm with client that all mandatory text sits at least 5mm inside the trim edge — preferably more for compliance content where legibility is required by regulation.
Export market considerations
If the wine is being labelled for export to international markets, additional compliance requirements may apply. Each export market has its own labelling regulations, which may be different from or additional to Australian requirements.
For trade customers: you don't need to be the expert on every export market's regulations. But you should recognise when a wine label is being prepared for export, and ensure the winery client is engaging with export-market compliance separately.
The Wine Export Label Directory (WALAS)
Since 1 July 2021, all wine exported from Australia must have its labels uploaded to the Wine Australia Licensing and Approval System (WALAS). This is a regulatory requirement on the exporter, not the printer or trade customer — but worth knowing that any wine label leaving Australia is part of a centralised registry.
Common export market additional requirements
- European Union: specific allergen declaration format requirements, lot code starting with "L," GI compliance for protected designations
- United Kingdom: post-Brexit regulatory framework with some divergence from EU requirements
- United States: TTB (Alcohol and Tobacco Tax and Trade Bureau) Certificate of Label Approval (COLA) required before sale
- China: bilingual labelling requirements, importer information requirements
- Other markets: varying requirements — winery client must consult market-specific regulatory advisors
This article doesn't attempt to cover export market compliance in detail — that's a specialist regulatory advisory area. Trade customers should simply recognise that export labels typically require additional compliance work and ensure the winery client is addressing it.
Frequently asked questions
Should I be checking my client's wine label for compliance before submitting it to Mediapoint?
You can choose to flag obvious issues you notice (missing pregnancy warning, old allergen wording, missing alcohol statement) — and most trade customers find this value-add helpful for their winery client relationships. But you are not the compliance authority and are not responsible for the artwork's regulatory compliance. The winery client owns that responsibility entirely. Your role is to receive, process, and submit the artwork accurately — and to communicate clearly with your client.
What if I notice a compliance issue but the client wants to proceed anyway?
Document the conversation in writing. If the client confirms they want to proceed with artwork that may have compliance issues, that's their decision and their responsibility. You should keep a record of the conversation (an email exchange is sufficient) confirming the client was informed and chose to proceed. This protects you from any subsequent dispute about whether the issue was flagged.
Does Mediapoint check artwork for regulatory compliance?
No. Mediapoint's prepress team checks artwork for technical print specifications — bleed, colour space, dieline configuration, white ink setup, font outlining, file format. We do not check for FSANZ compliance, Wine Australia compliance, or any other regulatory requirements. The supplied artwork is printed as supplied. Compliance is entirely the customer's responsibility.
Can Mediapoint advise on whether my client's artwork is compliant?
No. Mediapoint is a trade printer, not a regulatory advisor. For specific compliance questions, the winery client must consult FSANZ, Wine Australia, or a qualified regulatory advisor with specific expertise in wine label compliance.
Where can my winery client get authoritative compliance information?
The primary sources of authoritative wine label compliance information for Australian wine are:
- Food Standards Australia New Zealand (foodstandards.gov.au) — particularly Standard 2.7.1 (Labelling of alcoholic beverages) and Standard 1.2.3 (Mandatory advisory statements and declarations)
- Wine Australia (wineaustralia.com) — Label Integrity Program, Geographic Indications, export requirements
- Australian Competition and Consumer Commission (accc.gov.au) — Country of origin labelling requirements
- Australian Grape and Wine (agw.org.au) — industry peak body with regulatory guidance
For specific compliance advice, the winery client should engage a qualified regulatory advisor or compliance consultant with wine industry expertise.
Key takeaways
Wine label compliance in Australia is governed by FSANZ standards, Wine Australia requirements, Australian Consumer Law, and Country of Origin Food Labelling Information Standard 2016 — all of which can change.
Compliance responsibility belongs to the winery client. Mediapoint prints supplied artwork as a trade service and does not verify compliance. Trade customers can flag obvious issues but are not the compliance authority.
Mandatory elements on a compliant Australian wine label currently include: pregnancy warning mark, allergen declarations using prescribed plain English terms ("sulphites", "egg", "milk"), alcohol content statement, standard drinks declaration, country of origin statement, producer name and address, lot or batch identifier, and net contents (volume).
The pregnancy warning mark has a strict prescribed format. FSANZ publishes the official downloadable file — winery clients should use the supplied file rather than recreating the mark.
Allergen declarations must use prescribed plain English wording since 25 February 2024 — "sulphites" (not "sulfites"), "egg," and "milk." Old wording on new artwork is non-compliant.
Mandatory energy statements are coming. From 13 August 2028, packaged wine must include an energy statement in prescribed tabular format. Winery clients designing new labels now should be planning for this.
Vintage, variety, and origin claims (including Geographic Indications like Barossa Valley or Margaret River) are regulated under Wine Australia's Label Integrity Program. The winery client must maintain records substantiating any such claims.
Export market requirements are additional to Australian requirements. Winery clients exporting wine must engage with market-specific regulatory frameworks separately.
Working with Mediapoint on wine label production
Mediapoint prints digital roll labels for design studios, sign shops, and trade resellers servicing Australian winery clients. Standard turnaround starts from the next business day after file approval, for files received before the daily cut-off. Order minimum is $120 + GST per job. Trade pricing is available for design studios and resellers with regular wine label volume.
View our roll labels product page for current sizing options, material variants, and ordering. For broader wine label guidance covering materials, sizing, and file setup, the wine label printing pillar covers the full trade customer's brief.
A final responsibility note: the information in this article is general reference material based on Mediapoint's experience as a trade label printer and publicly available regulatory information current at the time of publishing. It is not legal or regulatory advice. Mediapoint does not provide compliance advice and does not verify the regulatory compliance of supplied artwork. The customer is solely responsible for ensuring artwork meets all applicable regulatory requirements before submission to print. For authoritative compliance information, consult FSANZ, Wine Australia, or a qualified regulatory advisor. Regulatory frameworks change periodically — verify current requirements directly with the relevant regulatory authority before relying on any general guidance from any source, including this article.
