The European Commission is running a consultation (TRIS) process for comment on the original Irish Public Health (Alcohol) Bill 2018. The consultation document can be found at TRIS consultation on a draft regulation for the Irish “Public Health (Alcohol) (Labelling) 2022 and is yet to be notified to the World Trade Organization.
The prescribed form of the warning, as outlined in the draft, raises a number of concerns (image below). There are the usual challenges of inconsistencies across requirements, unfavourable requirements on size, placement, colour, challenges in definitions of calorie calculations and lack of specified adequate transition period (the draft does not specify when it would enter into force but does conclude with the expected date of the regulation coming “into operation on __ ______ 2022”), of particular concern is the current wording used in the red warning texts.
The draft regulation appears to allow for over-stickering as a means of compliance.
Australian Grape & Wine is working with international colleagues in Europe and World Wine Trade Group members on options for responding to the draft regulation, with comments due via the TRIS consultation process until 22 September 2022.