Labelling Considerations...

Many thanks to Nick Bradstock of the NACM for sharing this information with the group:

The current position on this sort of thing, as understood by NACM, is below (although I can't cite sources or legal references from memory and E&OE!) For more legal input and some helpful general and specific guidance on these matters, try

1.    Ingredients list

All alcoholic beverages are exempt from carrying this.  The EU regularly seeks to update the Directive so as to require Member States to amend their national regulations to require ingredients lists for alcoholic beverages- and an attempt is being made even now - but the wine (of fresh grapes) lobby has so far successfully argued that it is not necessary for wine.  The other alcoholic beverage sectors (beer, spirits and cider/perry/fruit wine) are prepared to change but believe that all should change at once - so a bit of a stalemate there in spite of qualified majority voting in the EU COuncil.  The UK could go its own way but could not insist on imports carrying ingredients lists and so we are waiting for direction in the form of a new Directive - but no one is holding his or her breath.

Of course, you may do it voluntarily, as some already do, but then you must follow the full existing requirements as enshrined in general food law.

2.    QUID

Quantitative Ingredients Declarations are needed for all foods that claim high levels of something or give emphasis to a particular inclusion - Alcoholic beverages are not exempt from this even if they do not carry an ingredients list.  So, if you claim a specific variety or perhaps even show an apple on your label you should say what % of this item has gone into your product.  BUT, as far as I'm aware, this provision is yet to be tested on a cider maker's production and I presume that those labels that might have been examined were deemed acceptable.  This is a grey area.

3.    Best Before Date

Cider and perry are not required to carry a BBD since they are accepted as basically being best before for 2 years or more.  This is a very old provision in the Food Labelling Regs and might yet be challenged.  Beer must carry a BBD since the UK's brewers accepted that their products could not remain best before for more than 1 year and certainly not 2 years.

4.    Finally, Lot Number (or sometimes called Batch Code)

This is supplementary or even an alternative to BBD.  All consumer goods sold, and foods without exception and including alcoholic beverages, must carry a code, usually prefixed 'L' to determine a lot so that all that quantity can be identified if recall becomes necessary - clear records must be kept including destination on leaving the premises (this could be as simple as eg: 'my farm shop sale').  The size of the lot (and so the likely cost of any recall) may be determined more or less freely by the manufacturer.  Some try to keep it as small as possible - eg: a new lot every few minutes of the output of a mega-bottling line (you may even see the BBD showing packaging time in seconds) or the whole of one batch may be a 'lot' when batches are separated by days or more.  It's a balance between necessary control and the cost of an economic recovery.

It should be noted that Nick has provided this information on a personal basis to the Cider Workshop, and in response to a discussion that took place in November/December 2009. As with all information contained within this website, whilst we strive to maintain this information as current, we encourage individuals to check the facts for themselves.