Labelling

EU Spirits Regulation on Labelling
Regulation (EU) 2019/787 of the European Parliament details the definition, description, presentation and labelling of spirit drinks. This basically sets out the rules on the use of the names of spirit drinks in the presentation and labelling of other foodstuffs and the protection of geographical indications (PGIs) for spirit drinks. This is of a particular interest to Irish Whiskey, Irish Cream and Poitín which have been granted a geographic protection under GI regulations. This helps safeguard the reputation of spirit drink categories and GIs and to prevent consumers’ deception

 

Relevant EU Spirits Regulations Documents: EU Spirits Regulations

Details of GI Protection of Irish Whiskey: GI on Irish Whiskey

Details of GI Protection for Irish Cream: GI on Irish Cream

Details of GI Protection for Poitín: GI on Poitín

 

Country of Origin labelling
Regulation (EU) 2018/775 came into effect on the 1 April 2020. It requires that where the country of origin of a final food (or drink product) is displayed on a label and where this is not the same as the origin of the primary ingredient, then the origin of the primary ingredient must also be written on the label.

For example, where the origin of a cider is declared as Irish on the label but the apples used for the product are not Irish, then it will be a legal requirement to also give the origin of the apples on the label. This is to ensure the consumer is not mislead.

Origin (of a product) can be indicated on a label by various statements such as words, pictures (map, scene), symbols (flags), words/terms or colours/designs that refer to a geographical origin.

This Regulation shall not apply to geographical indications protected under Regulation (EC) No 110/2008 and Regulation 2019/787.

What is the Primary Ingredient?

'Primary ingredient' is defined in Regulation 1169/2011/EC as ‘an ingredient or ingredients of a food that represents more than 50% of that food or which are usually associated with the name of the food by the consumer and for which in most cases, a quantitative indication is required’ i.e a QUID declaration. It will be up to each food business operator to determine what is the primary ingredient of their drink.

If the drink contains an ingredient that is >50%, then this is straightforward. Where the drink does not have an ingredient >50%, then the ingredient(s) most associated with the drink (and where that drink has a QUID declaration) will be considered as the primary ingredient. This directive is applicable to cider products because of apples, however beer is not covered by this directive as the FSAI deem water as its primary ingredient and since all water for beer production is locally sourced then it does not require a country of origin declaration on the label.

More details can be found here.

The drinks industry is committed to providing consumers with meaningful, relevant information that helps them make responsible decisions. Drinks companies in Ireland often voluntarily provide information to consumers, anti-drink/drive logos, energy values, ingredient information and pregnancy warnings.

Memorandum of Understanding (MoU) with the European Commission

In 2019 Drinks Ireland | Beer signed an MoU with the European Commission which commits the brewing sector to include nutrition and ingredient information on all pre-packaged beer products. 

Drinks Ireland | Spirits also signed an MoU with the European Commission which committed the sector to include nutritional information on pre-packaged spirits products and ingredient information on brand websites.

Section 12 of the Public Health (Alcohol) Act 2018 requires alcohol product containers to provide the following warnings and health information as set out in Schedule 1 of the Regulations. Commencement date 22 May 2026. 

• A warning to inform the public of the danger of alcohol causing liver disease;
• A warning to inform the public of the danger of alcohol consumption when pregnant;
• A warning to inform the public of the direct link between alcohol and fatal cancers;
• The quantity of grams of alcohol contained in the product;
• The energy value expressed in kilojoules and kilocalories contained in the alcohol product,
• Details of a website run by the Health Service Executive providing information on alcohol and related harms.

Alcohol products sold in kegs or casks will have an accompanying document with the above information. Licensed premises will have a notice(s) in the legally prescribed form with above warnings and website information, confirming that a document noting the alcohol content and energy value of every product for sale in the premises is available on request. The above information will also be required to be displayed on any website that sells alcohol online.