Market Access Update – United Kingdom (UK)

UK wine regulatory reform

As noted in previous updates, the UK is undergoing significant reforms of its wine regulation under a phased approach. Both phase one, which was implemented in January 2024 and phase two, which will come into force in July 2024, are now complete.

On 16 April 2024 the UK began consultation on phase three of the reforms, a raft of changes that may have the most significance for Australian wine exports, as they relate to on-processing provisions and no and low regulation, amongst other areas. Australian Grape & Wine and Wine Australia have been working with a number of producers to coordinate a collective response to this consultation. Responses to this consultation were provided in May and we are now continuing to work with the UK government in support of liberalisation of their wine regulations.

UK Extended Producer Responsibility

The UK is in the process of establishing Extended Producer Responsibility (EPR) requirements for packaging, some of which is coming into effect in 2024. These requirements state that organisations that supply or import packaging must:

  • Collect and report data on the packaging they supply or import;
  • Pay a waste management fee;
  • Pay scheme administrator costs;
  • Pay a charge to the environmental regulator;
  • Get packaging waste recycling notes (PRNs) or packaging waste export recycling notes (PERNs) to meet their recycling obligations;
  • Report information about which nation in the UK packaging is supplied in and which nation in the UK packaging is discarded in, also known as “nation data.”

The specific actions that need to be taken will depend on whether an organisation is considered small or large, based on their annual turnover and the amount of packaging they supply or import each year. In certain circumstances, Australian wine producers may have responsibilities that they will need to comply with in relation to these new EPR requirements. At this stage we understand that this is limited to reporting requirements and that fees have been deferred and will not start until October 2025. In particular those who export branded, finished product in bottles into the market may have responsibilities under the UKs EPR.

To understand what may apply to your business, more information is available at the UK government website here

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