Labelling Imported Bulk Spirits for Sale in South Africa

VKM Liquor LLP

4 days ago

5 min read

Updated: 3 hours ago

A brand that imports bulk spirit and bottles it in South Africa has one more compliance layer to clear after the licence and the duty: the label itself. Labelling of spirits is governed by the regulations under the Liquor Products Act 60 of 1989, and they are specific about what must appear, how it must be worded, and where on the container it must sit.

This guide covers what those regulations require of a spirit label, with particular attention to the rules that catch out brands bottling imported liquid.

The particulars every spirit label must carry

Regulation 33 sets the compulsory particulars for a spirit sold in South Africa:

The class designation
The alcohol content
The country of origin
The name and address, or registered code number, of the responsible seller
The filling date
Lot identification

Two exemptions are worth noting. The country of origin may be left off a spirit produced in South Africa, which is precisely why it cannot be left off an imported one. The filling date may be omitted on glass containers. Lot identification applies to products filled after 30 June 2012.

Country of origin is where imported brands slip

Regulation 37 does not let you simply print a country name. The wording is prescribed, and which wording applies depends on where the liquid was made and where it was bottled.

If the spirit is produced and bottled in the same country, the label reads "Produced and bottled in" followed by that country. If it is produced in one country and bottled in another, which is the normal position for a South African brand importing bulk, the label reads "Produced in" the country of production, then "and bottled in" the country of bottling.

So a brand importing Indian bulk spirit and bottling it locally carries wording to the effect of "Produced in India and bottled in the Republic of South Africa". That is not optional and it is not something to decide at artwork stage; it follows from the supply chain.

Where a bottling blends imported and local spirit, regulation 37 requires the producing countries to be listed in descending order by volume, followed by the bottling country. Change the blend ratio and the label changes with it.

The class designation is a closed list

You cannot invent a category. Regulation 35 requires the label to carry one of the spirit classes set out in the regulations: whisky, malt whisky, blended whisky, grape spirit, husk spirit, premium husk spirit, pot still brandy, brandy, vintage brandy, cane spirit, rum, gin, vodka, unspecified spirit or mixed spirit.

Each of those classes has its own definition elsewhere in the regulations, and the liquid has to meet it. A spirit that does not fit any named class is sold as an unspecified spirit, and the label must then identify the fermented article it came from, either in place of the word unspecified or after wording such as "Spirit distilled from".

A blend of two or more classes is a mixed spirit, labelled "A mixture of" followed by the component classes in descending order by volume of absolute alcohol.

This is the point at which a sourcing decision becomes a labelling decision. If a brand wants the word whisky on the bottle, the imported liquid has to satisfy the regulation's definition of whisky. Buying on price alone and sorting out the category later is how brands end up relabelling a shipment.

Minimum alcohol strengths

Regulation 36 sets minimum strengths, and they are higher than many first-time importers expect. For whisky, malt whisky, blended whisky, brandy, rum, gin, vodka, cane spirit, grape spirit, husk spirit, unspecified spirit and mixed spirit, the minimum is 43% alcohol by volume. Premium husk spirit sits at 40%. Pot still brandy and vintage brandy bottled after 31 December 2013 sit at 38%.

That floor decides your dilution maths. A 43% minimum on the finished bottle, worked backwards through blending and reduction, sets how much bulk spirit each case actually consumes, and therefore your landed cost per case.

The content itself is shown as a figure followed by the percentage symbol and the word alcohol or volume, or an accepted abbreviation. The stated figure may not differ from the actual content by more than 0.5.

How the particulars must be laid out

Regulation 34 governs presentation, and it is stricter than general food labelling. Every compulsory particular except the filling date and the lot identification must appear in the same field of vision, on one or more labels permanently attached to the container. Spreading the class designation across the front and the country of origin across the back does not satisfy it.

Each particular must be clearly distinguishable from the others and from the rest of the label. Within each particular the letters and figures must be the same colour, type and size, on a uniform and clearly contrasted background, clearly legible and permanently printed. Minimum letter heights are set by container capacity in Table 9 of the regulations.

Lot identification is exempt from the colour, type, size and height rules, but still has to be legible and permanent.

Filling date, lot code and the responsible seller

The filling date is written as "Filled on" followed by the date in day, month, year order. Glass containers are exempt.

Lot identification is any mark identifying the batch, preceded by the letter L.

The responsible seller is shown either by the name and address appearing on that seller's liquor licence, by an approved name and full physical business address, or by a code number registered under regulation 40. A company must use its full registered name.

What this means when you buy bulk

Three of these requirements are settled before the liquid ever reaches a bottling line, and all three depend on the supplier.

Class. The liquid must meet the regulation's definition of the class you intend to print. Confirm it against the definition before the order, not after landing.
Strength. A 43% floor on most classes means the delivered strength and your reduction plan have to be worked out together.
Country of origin. The production country is fixed by where the spirit was distilled, and it goes on the label.

VKM Liquor supplies bulk whisky, malt spirit, vodka, gin, rum and extra neutral alcohol from our distillery in Himachal Pradesh, India, with declared strength and a certificate of analysis on every consignment, so the class and strength questions are answered in writing before you commit.