By volume, most Australian wine is exported. The United Kingdom has been a major export market for Australian wines since the 1990s. It is Australia’s number one export destination by volume. It is also Australia’s third largest export destination by value: $380 million worth of wine was exported to the UK from Australia in the 12 months prior to September 2018.

In January 2019, the Federal Senate passed the Australia-United Kingdom Agreement on Trade in Wine, which will allow wine exports to continue to flow to Britain post-Brexit. The treaty notes, “…this Agreement shall apply, in respect of the United Kingdom, to the United Kingdom and the territories for whose international relations it is responsible to the extent that and under the conditions which the EC-Australia Wine Agreement applied immediately before it ceased to apply to the United Kingdom.”

The Wine Australia website has noted that the UK has introduced its own version of the VI-1 document required to accompany most shipments of wine into the EU. This certificate is almost identical to the standard EU certificate, but with references to the EU replaced with references to the UK.

A VI-1 form is a document, issued in the home market of a wine exporter, that fully describes wines – a certificate of chemical analysis. What happens to VI-1 forms post-Brexit for shipments of Australian wine that have entered the UK, and are then trans-shipped to the 27 continental EU member states? Such indirect shipments involve bulk Australian wine packaged in the UK prior to trans-shipment, and packaged wine that is split from a UK-bound consignment and on-sold to European markets. Wine Australia estimates least 100,000 such transactions occur annually. Article 59 of European Commission (EC) regulation 479/2008 requires the label of an imported wine to indicate the name and address of the importer. Article 56 of EC regulation 607/2009 defines the importer to be a person ‘established within the EU’. But, post-Brexit, no person based in the UK will meet this definition. A wine sold in any of the 27 EU member states other than the UK will therefore need to indicate the details of an importer established in one of those 27 remaining countries.

Like much of Brexit, there are no clear answers to these concerns. The obvious work-around seems to be the appointment of importers in Continental Europe.