The new regulation brings numerous changes in labelling rules for spirits sold in the EU.
Detailed provisions have been introduced in the contentious areas of compound terms and allusions and the labelling of mixtures (and blends).
Rules for the use of spirits category names on other products are more comprehensive: in some respects they are more restrictive; in others more permissive.
In the spirits sector, only liqueurs can make allusions to their alcohol components. These rules are extremely permissive.
New rules for cream liqueurs, however, are much more restrictive than at present.
In some other sectors there is total freedom to refer to protected names, even when the spirit has not been used.
New rules for blends will, in some cases, mean the product has to be labelled as a ‘spirit drink’.
Some of the labelling rules are ambiguous and need to be clarified. To try to avoid enforcement difficulties, producers need to know where the uncertainties arise.
Efforts will be required by spirits producers to secure acceptable clarification of, and probably changes to, the regulation before May 2021.