16 July 2021
- Russian “Shampanskove” and Russian cognac are causing a headache: Are Russia’s new labelling rules for alcoholic beverages WTO compatible?
Russian “Shampanskove” and Russian cognac are causing a headache: Are Russia’s new labelling rules for alcoholic beverages WTO compatible?
On 2 July 2021, the President of Russia Vladimir Putin signed the Federal Law N 345-FZ on Amendments to the Federal Law on State Regulation of the Production and Turnover of Ethyl Alcohol, Alcoholic and Alcohol-Containing Products and on Restricting the Consumption (Drinking) of Alcoholic Products and Certain Legislative Acts of the Russian Federation (hereinafter, Federal Law N 345-FZ). Federal Law N 345-FZ amends the classification of ‘alcoholic products’, notably, changing the legal definition for Champagne sparkling wine and introducing the classification for ‘Russian cognac’. Additionally, the law imposes new labelling requirements for imported products. The new rules have raised concerns regarding their impact on trade and questions about their compatibility with WTO rules.
Key elements of Federal Law N 345-FZ affecting Champagne
The Federal Law N 345-FZ amends Federal Law N 171-FZ on State Regulation of the Production and Circulation of Ethyl Alcohol, Alcoholic and Alcohol-Containing Products and on the Limitation of Consumption (Drinking) of Alcoholic Products of November 22, 1995. One of the main amendments introduced by Federal Law N 345-FZ is the new classification for alcoholic products. Article 2(7) of Federal Law N 345-FZ distinguishes between “alcoholic beverages (including vodka, cognac, grape vodka, brandy), wine, fortified wine, sparkling wine, including Russian champagne, grape-containing drinks, fruit alcoholic products, fruit alcoholic beverages, beer and drinks made on the basis of beer, cider, poiret, mead”. The previous classification had listed alcoholic products as “alcoholic beverages (including vodka, cognac), wine, fruit wine, liqueur wine, sparkling wine (champagne), wine drinks, beer and drinks made from beer, cider, poiret, mead”. Thus, the new classification eliminates the reference to Champagne, which now falls under sparkling wine, but introduces the new classification of ‘Russian champagne’. The removal of the term Champagne from the classification means that the term is also removed from all other legal provisions, maintaining only the option of ‘sparkling wine’ and Russian ‘shampanskove’, which means Champagne in Russian. On the basis of the new rules, imported sparkling wine, including French Champagne, will have to be labelled as “sparkling wine”, while the term ‘shampanskove’ may only be used for “Russian champagne” sparkling wine.
Additionally, the amendments introduce the requirement for all imported wines and sparkling wine, including Champagne, to use a back-label on the bottles indicating, in Russian, the new classification for alcoholic products. Therefore, French Champagne producers must include a back-label with the description ‘sparkling wine’. The new legislation still allows French Champagne producers to continue using their own brand label and the term Champagne in Latin characters, but requires them to add a back-label that provides, in Russian, the classification ‘sparkling wine’ (i.e., igristoye vino in Russian) instead of ‘champagne’ (i.e., shampanskove in Russian). Notably, according to the new legislation, Russian producers of ‘Russian champagne’ would be allowed to continue using the term ‘shampanskove’ in Cyrillic characters, as the classification of ‘Russian champagne’ has been introduced in the classification of alcoholic products. In this regard, Federal Law N 345-FZ states that “wineries producing sparkling wine on the territory of the Russian Federation from grapes grown on the territory of the Russian Federation […] have the right to indicate the name ‘Russian champagne’ on the label of such products”.
Federal Law N 345-FZ does not provide any transitional period for producers to adapt to the new labelling rules, as it applies from the day of publication in the official Russian Gazette. Therefore, changes must take place immediately for the imported product to be placed on the Russian market and to avoid fines for non-compliance.
Another peculiar element of Federal Law N 345-FZ is that the “use of the names of geographical objects located on the territory of the Russian Federation, including words derived from these names, on the label and back-label of wine products, (…) may be carried out only by wineries producing Russian wine products of protected names (…), and only in relation to Russian wine-making products”. It appears that any reference indicating the protection of wine as a geographical indication (GI) is only permitted to be used for Russian-protected GIs, since no indication is allowed on the labels of imported wine. Therefore, wines from the Bordeaux and Rioja regions, for instance, as well as other wines carrying a protected GI, appear to be now required to change their back-labels and to eliminate the reference to the geographical origin, only maintaining the classification “wine”. However, the rules are not clear and further clarification in this regard would be necessary.
Introducing ‘Russian Cognac’
Federal Law N 345-FZ further introduces provisions that will affect the placing on the Russian market of Cognac. More specifically, Federal Law N 345-FZ introduces the term ‘Russian cognac’, which is defined as “cognac completely (100 percent) produced from grapes grown on the territory of the Russian Federation”. It is unclear whether the term Cognac may no longer be used on imported products. Federal Law N 345-FZ states that “within seven years from the date of entry into force of this Federal Law, processing or use of cognac distillate produced outside the territory of the Russian Federation is allowed for the production of cognac”, but does not provide further specifications. The provision appears to state that, after seven years, the use of the term Cognac would be prohibited on imported products. However, further clarification on this provision is needed. Finally, Federal Law N 345-FZ amends Article 26(7) of the Federal Law of 27.12.2019 N 468-FZ on viticulture and winemaking in the Russian Federation stating that “wineries producing cognac completely (100 percent) made from grapes grown on the territory of the Russian Federation have the right to indicate the name ‘Cognac of Russia’ on the label of such products”.
France’s Champagne and Cognac manufacturers react
Champagne and Cognac are protected names in France under the French appellation d’origine contrôlée (AOC) system and make reference to sparkling wine and brandy produced in the Champagne and Cognac regions, respectively. Both names, Champagne and Cognac, are also protected under the EU’s Protected Designation of Origin (PDO) and Protected Geographical Indication (PGI) schemes, respectively. GIs are defined in Article 22 of the WTO Agreement on Trade-Related Aspects of Intellectual Property Rights (hereinafter, TRIPs) as “indications which identify a good as originating in the territory of a Member, or a region or locality in that territory, where a given quality, reputation or other characteristic of the good is essentially attributable to its geographical origin”. The legal concept of GIs as Intellectual Property Rights (IPRs) aims at providing legal protection against imitations and usurpations of products, particularly food and agricultural products. The protection through GIs focuses on preventing the misuse of names, which could mislead consumers as to the origin of agricultural products and their quality or characteristics, which provide added culinary and economic value.
The Champagne Committee, which is the trade association that represents the interests of independent (French) Champagne producers, stated that it opposes Russia’s new legislation, noting in a statement that “this regulation does not provide Russian consumers with clear and transparent information on the origin and characteristics of wines. It regrets that this new law calls into question more than twenty years of bilateral discussions between France and Russia on the protection of designations of origin”. The statement notes that the Champagne Committee “is currently analysing the details and consequences of this law, of which it had not been informed by the Russian authorities”. The previous legislation allowed Champagne producers to use the word ‘shampanskove’ on their labels, while, under the new legislation, this term is only allowed for Russian sparkling wine. In its statement, the Champagne Committee points out that the name Champagne is protected in over 120 countries and called on the French Champagne industry to suspend its exports to Russia.
Annually, Russia imports around 50 million litres of sparkling wines and Champagne, of which 13% is Champagne from France. In 2020, Champagne exports from France to Russia increase 10% to around 1.9 million bottles for a total value of EUR 35 million. The Champagne Committee stated that the new law would cause financial losses, as producers are currently “unable to export Champagne to the Russian market”, since changing the labels on bottles ready to be shipped would be technically and financially challenging.
A possible WTO dispute?
The amendments adopted under Federal Law N 345-FZ have raised concerns regarding their compatibility with the rules of the World Trade Organization (hereinafter, WTO). The new rules could be in violation of certain provisions of the General Agreement on Tariffs and Trade (GATT) and the TRIPs Agreement.
Article III(4) of the GATT provides that “products of the territory of any contracting party imported into the territory of any other contracting party shall be accorded treatment no less favourable than that accorded to like products of national origin in respect of all laws, regulations and requirements affecting their internal sale, offering for sale, purchase, transportation, distribution or use”. The name Champagne has the reputation and prestige as a quality product, which contains specific characteristics in its way of production and the region where it is produced (i.e., France’s Champagne region). While the new rules do not prohibit the use of the term Champagne on the bottles originating in France, only the use of the term in Latin characters is allowed. The term ‘shampanskove’, champagne in Russian, may only be used in Cyrillic characters for the “Russian champagne”. This could be considered discriminatory, as it provides an advantage to domestic ‘like’ products, given that only Russian producers will be able to use the term champagne in Russian and in Cyrillic characters. With respect to the issue of ‘likeness’ under Article III of the GATT on ‘National Treatment on Internal Taxation and Regulation’, different processing methods cannot be used to classify two ‘like’ products as different. Therefore, although the production process of Champagne in France differs from the production of ‘Russian champagne’, they should be considered to be ‘like’ products.
Article 23(1) of the TRIPs Agreement grants a particularly high standard of protection to geographical names of wines and spirits. More specifically, any use of misleading indications is prohibited, even if the true origin of the goods is stated, or if the geographical indication is used as a translation or accompanied by expressions such as ‘kind’, ‘style’ or ‘type’. Article 24(4) of the TRIPs Agreement constitutes a grandfathering clause, which protects GIs used by any WTO Member’s nationals or domiciled residents in a continuous manner for at least ten years before 15 April 1994, or in good faith prior to that date. Therefore, the EU could argue, in a potential WTO dispute, that Federal Law N 345-FZ is incompatible with the TRIPs Agreement and violates Article 23 of the TRIPs Agreement, as the amended legislation will only allow the use of the term champagne for domestic Russian sparkling wine, thereby potentially misleading consumers.
On 6 July 2021, the French Minister for Europe and Foreign Affairs Franck Riester, in charge of Foreign Trade, stated that, together with the EU, France would not hesitate to pursue legal action against Russia at the WTO, if necessary. A spokesperson for the European Commission stated that the European Commission would “do everything necessary to protect our rights and take the necessary steps if this law enters into force”. It appears that the EU is currently analysing the amendments and determining the next steps. All affected stakeholders, particular wine, Champagne, Cognac and spirit producers, should closely monitor these Russian legislative developments, as the new rules could have significant impact on trade and competition on the Russian market.
In an effort to simplify overlapping regulations and business licensing procedures, Indonesia’s Law No. 11 Year 2020 concerning Job Creation (hereinafter, Job Creation Law) introduced the concept of ‘risk-based’ business licensing. On 2 February 2021, the Government of Indonesia then issued Government Regulation No. 5 Year 2021 concerning Organization of Risk-Based Business Licensing (hereinafter, GR No. 5/2021), an implementing regulation to the Job Creation Law. GR No. 5/2021 introduced criteria on how business licenses in 16 business sectors in Indonesia are to be issued, namely based on the assessment of the risk level of the respective business activity. The introduction of the risk-based approach aims at simplifying the requirements for business actors, as not all sectors will be subject to licensing requirements. In general terms, the lower the ‘business risk’, the simpler the business licensing requirements.
Rationale: Simplifying the issuance of business licenses in Indonesia
In the past, the Government of Indonesia has been applying a rather strict and complex licensing approach, which required business actors to obtain different types of licenses before being able to commence their business activities in Indonesia. Investors, particularly foreign ones, often complained about the difficulty and time-consuming process of obtaining all necessary business licenses. A 2020 survey showed that, of 2,003 respondents, 53% said that it was either “hard” or “very hard” to obtain a business license for foreign operators and Indonesian small and medium-sized enterprises (SMEs).
Excessive and overlapping regulations between Indonesia’s Central and Regional Governments, coupled with institutional inefficiencies, also appear to have been the major impediments in recent years to attract foreign investment into Indonesia. The existence of 8,451 Central Government regulations and 15,965 Regional Government regulations clearly indicates the complexity and fragmentation of Indonesia’s regulatory framework. Between 2018 and 2019, Indonesia was listed at the 73rd position in terms of ‘ease of doing business’, according to the World Bank’s 2020 Doing Business Index. This situation has led the Government of Indonesia to issue the Job Creation Law, which is supposed to stimulate domestic and foreign investment by removing bureaucratic inefficiencies and excessive licensing requirements.
Risk-based business licensing in a nutshell
Under GR No. 5/2021, all businesses operating in Indonesia are required to comply with several requirements before they may commence to carry out business activities: 1) Basic requirements for business licensing (i.e., utilization of space, environmental approval, building approval and certificate of worthiness); and/or 2) Risk-based licensing requirements that apply to 16 sectors, including marine and fisheries, energy and mineral resources, and trade. GR No. 5/2021 prescribes three types of risk-based business licensing, namely the Business Identification Number, the Certificate of Standards, and the Permit.
The term ‘risk’ is defined as the potential for injury, or loss from a hazard, or a combination of possibilities and consequences of danger. In order to determine the risk level, the Government of Indonesia will carry out a risk analysis of each application, consisting of the following stages: 1) Assessment of the hazard level; 2) Assessment of the potential occurrence of hazards; 3) Determination of the risk level and business scale rating; and 4) Determination of the type of business license(s) required. The type of risks recognised as benchmarks under GR No. 5/2021 vary, ranging from health and safety risks to the environmental risks, the use and management of natural resources, and the location of the business activity.
Based on the risk analysis, the business activities that will be undertaken by the applicant are classified into one of the following risk-level types: 1) Low-risk business activities (e.g., department stores and soybean tempeh industry); 2) Medium-low risk business activities (e.g., fishing of finned sea fish and fish oil industry by small and medium-sized enterprises); 3) Medium-high risk business activities (e.g., port service activities); and 4) High-risk business activities (e.g., distribution of natural and artificial gas, and provision of internet services). A business activity’s level of risk determines the business licensing requirements.
Scope and licensing requirements of each of risk-level of business activities
For each of the four levels of risk, the GR No. 5/2021 prescribes the respective licensing requirements. The risk-based approach allows the verification of compliance by business actors with certain business standards after they have commenced certain business activities. In contrast, under Indonesia’s previous approach to business licensing, known as ‘commitment-based’ licensing, business actors were required to fulfil certain standards in advance of the commencement of any types of operation.
Under Article 17 of GR No. 5/2021, business activities are classified into two categories, namely the preparation stage, as well as the operational and/or commercial stage. The preparation stage includes, inter alia, land acquisition, the construction of buildings, the procurement of human resources, and the fulfilment of business standards. The operational and/or commercial stage consists of the actual business activities, such as the production, distribution, and marketing of goods/services. It is important for investors to take note of what types of activities are allowed to be carried out on the basis of each licenses.
The following licensing requirements must be considered:
Level of risk
Required business licensing
Specific requirements for each business sector and the related activities
The specific risk categories for each business activity, along with the scope and scale of the business activity, are listed in Appendix I to GR 5/2021. A different business scale or scope within the same business sector may be categorised into a different risk level. With respect to hotels, for instance, hotels with less than 61 rooms or less than 41 employees within a micro, small and medium business scale on a land area of less than 4,000 m2 are classified as a low-risk business activity, while hotels with 61 to 100 rooms or 41 to 99 employees within a micro, small, medium and large business scale on a land area of between 4,000 to 6,000 m2 are classified as a medium-low risk business activity.
The requirements for business licensing in each sector are listed in Appendix II to GR No. 5/2021. For example, for the fish freezing industry, business actors are required to obtain a Processing Eligibility Certificate, a Hazard Analysis and Critical Control Point Certificate (HACCP), and a Business Activity Report. Meanwhile, guidelines that cover, inter alia, the assessment of potential hazards, standards of implementation (e.g., aspects of health and safety, environment), and conformity assessment with the of risk-based licensing, are provided in Appendix III to GR No. 5/2021.
The standards, procedures and criteria of business licensing in the 16 business sectors that will be subject to the implementation of risk-based business licensing covered by GR No. 5/2021 vary and are further regulated by ministerial or head of institutions regulations. To avoid overlapping rules between Central and Regional Governments, the Central Government will determine the standards, procedures, and criteria of business licensing, which then become the sole reference for the issuance of business licenses throughout the country. Some regulations have already been issued, such as within the health, environment and forestry sectors.
What to expect from the new licensing approach?
Despite the GR No. 5/2021 having already entered into force, the new rules are not yet being implemented by the Government of Indonesia. The official implementation was originally foreseen for 2 June 2021, it was then rescheduled to 2 July 2021, but Indonesia’s Ministry of Investment recently confirmed that the deadline has now been extended for an uncertain period of time, as the Government is still preparing and updating the Online Single Submission (OSS) system, which is going to process the risk-based business licensing.
The introduction of a risk-based licensing approach appears to be a positive development for economic operators intending to conduct business in Indonesia and might improve Indonesia’s investment climate. Notably, business licensing for the business actors within the low to medium-low risks will be greatly facilitated. However, pending the actual implementation of GR No. 5/2021, it is too early to determine the real effectiveness and efficiency of the risk-based licensing system and whether or not the new system will indeed address Indonesia’s long-standing issues of excessive and overlapping regulations, and its institutional inefficiencies. Business actors should diligently monitor this development and check the relevant requirements for their business activities in Indonesia.
In four rulings of 7 July 2021, the UK Advertising Standards Authority (hereinafter, ASA), the UK’s independent advertising regulator, upheld complaints against four hard seltzer beverage producers for unlawfully making nutrition and/or health claims for their respective beverages in their advertising. Wikipedia defines ‘hard seltzer’, ‘spiked seltzer’ or ‘hard sparkling alcohol water’ as “a type of highball drink (i.e., mixed alcoholic drink) containing carbonated water, alcohol, and often fruit flavourings” with alcohol by volume (hereinafter, ABV) of around 5% and with a relatively low calorie-content, whereby “in the US the alcohol is usually made by fermenting cane sugar; sometimes malted barley is used” and “Hard seltzer products outside of the US have been found to use either neutral spirit, or fermentation of fruit”.
UK Advertising Regulations after ‘Brexit’
In the UK, the ASA ensures that advertisements in UK media respect the advertising rules (i.e., the Advertising Codes). The Committee of Advertising Practice (CAP) is responsible for drafting the Advertising Codes. The UK Code of Non-broadcast Advertising and Direct & Promotional Marketing (hereinafter, CAP Code) is the rule book for non-broadcast advertisements, sales promotions and direct marketing communications. Before the UK’s withdrawal from the EU, the CAP Code required, inter alia, that only nutrition claims listed in the Annex to Regulation (EC) 1924/2006 on nutrition and health claims on foods be permitted in advertisements promoting foods or drinks. From 1 January 2021, only nutrition claims authorised on the Great Britain nutrition and health claims (NHC) register are permitted in marketing communications. The CAP Code defines a nutrition claim as “any claim which stated, suggested or implied that a food (or drink) had particular beneficial nutritional properties due to the amount of calories, nutrients or other substances it contained, did not contain, or contained in reduced or increased proportions”. The CAP Code further states that the only permitted nutrition claims that may be made in relation to alcohol are ‘low-alcohol’, ‘reduced alcohol’ and ‘reduced energy’. ‘Health claim’ means “any claim that states, suggests or implies that a relationship exists between a food category, a food or one of its constituents and health”. The CAP Code does allow alcoholic beverages to give factual information about a product, such as the calorie content (e.g., ‘90 calories per can’).
Four advertising complaints upheld by the UK ASA
In July 2021, the ASA upheld complaints against four hard seltzer beverage producers for unlawfully making nutrition and/or health claims for their respective beverages in their advertising. The first advertising for BrewDog’s Clean & Press hard seltzer posted on the social media application Instagram on 21 January 2021 included an image of a can of the beverage and the phrase “Due to advertising regulations we cannot claim this drink is healthy”. Furthermore, below the image, it stated “Even though Clean & Press is only 90 calories per can, with no carbs or sugar and a little bit of alcohol, this is not a health drink. If you are looking for a health drink, do not drink Clean & Press”. The ASA considered, in its ruling of 7 July 2021, that the advertising consisted of both health and nutrition claims. According to the ASA, the Instagram advertisement would lead consumers to believe that, while the drink was, in fact, healthy, this was merely not allowed to be stated. The ASA considered that the advertisement implied that the beverage was beneficial to overall good health or health-related well-being. The claim “no carbs or sugar” equated to a nutrition claim, while the phrase “only 90 calories” (as opposed to stating “90 calories”) was a prohibited nutrition claim, according to the ASA. The ASA held that the claim ‘a little bit of alcohol’ implied that the drink had a low alcohol content, which was considered misleading because it had an alcoholic strength by volume (ABV) of 5%.
The second complaint concerned the Long Ashton Holdings Ltd t/a High-Water hard seltzer, which, similarly, used the phrase “under 100 calories per can”. Again, the ASA, in its ruling of 7 July 2021, considered this to be a nutrition claim because the word ‘under’ could “suggest the drink had the particular beneficial nutritional property of being low in calories”. High-Water has reportedly announced that it would change the messaging to ‘ranges from 93-99 calories per can’.
The third advertisement was also made on Instagram for the hard seltzer beverage DRTY DRINKS, using the hashtags #lowcalorie, #nosugardiet, #zerosugar, #keto, #carbfree and #nocarbs. The ASA, in its ruling of 7 July 2021, considered that the advertisement made a nutrition claim in relation to alcohol. DRTY has reportedly announced not to use the hashtags again.
Finally, the complaint against an advertisement for the fourth hard seltzer beverage Wild Drinks Group’s Whisp Drinks was also upheld by the ASA in a ruling of 7 July 2021 for the description “refreshing, low calorie, lightly alcoholic sparkling water – the perfect accomplice to a balanced lifestyle”, as well as “Milk thistle: natural detox hero” and “healthier choice: low in sugar, calories and alcohol” as prohibited health claims. Whisp reportedly stated it that it would remove the claims from its website.
Prohibition of health claims for alcoholic beverages and most nutrition claims in the EU
In the EU, Article 4(3) of Regulation (EC) No 1924/2006 of the European Parliament and of the Council of 20 December 2006 on nutrition and health claims made on foods provides that “Beverages containing more than 1,2 % by volume of alcohol shall not bear health claims. As far as nutrition claims are concerned, only nutrition claims referring to low alcohol levels, or the reduction of the alcohol content, or the reduction of the energy content for beverages containing more than 1,2 % by volume of alcohol, shall be permitted”. Under Article 4(4) of Regulation (EC) No 1924/2006, in the absence of specific EU rules regarding nutrition claims referring to low alcohol levels, or the reduction or absence of alcohol or energy in beverages, which normally contain alcohol, relevant national EU Member States’ rules may apply. The criteria for making ‘energy-reduced’ nutrition claims are set out in the Annex to Regulation (EC) No 1924/2006: “A claim that a food is energy-reduced, and any claim likely to have the same meaning for the consumer, may only be made where the energy value is reduced by at least 30 %, with an indication of the characteristic(s) which make(s) the food reduced in its total energy value”.
Health claims for alcoholic beverages have been subject to legal proceedings in the EU. In the preliminary judgment of 6 September 2012, in the Case C-544/10 Deutsches Weintor eG v Land Rheinland-Pfalz, the Court of Justice of the European Union (hereinafter, the CJEU) established that wine may not be promoted and labelled as being ‘easily digestible’ (see Trade Perspectives, Issue No. 17 of 21 September 2012). In its preliminary judgment, the CJEU established that the prohibition against using health claims to promote beverages containing more than 1.2% ABV covers the description ‘easily digestible’, accompanied by a reference to the reduced content of substances frequently perceived by consumers as being harmful. Therefore, the interpretation of health claim is quite wide and includes implicit messages.
Nutrition labelling of alcoholic beverages in the EU
Article 16(4) of Regulation (EU) No 1169/2011 of the European Parliament and of the Council of 25 October 2011 on the provision of food information to consumers (Food Information Regulation, FIR) exempts alcoholic beverages containing more than 1.2% ABV from displaying the mandatory list of ingredients (with the exception of ingredients that may have an allergenic effect) and the nutrition declaration, which became mandatory for all foods, with few exceptions. In the process of adopting the Food Information Regulation, harmonised requirements for the labelling of alcoholic beverages could not be agreed on. In September 2018, a spokesperson for the European Commission (hereinafter, Commission) stated that the Joint self-regulatory proposal from the European alcoholic beverages sectors on the provision of nutrition and ingredients listing (hereinafter, the Joint Proposal) submitted to the Commission on 12 March 2018 had “some legal issues” and did “not satisfy the need to fully inform EU consumers”. The Commission was thereby hinting at the eventual regulation of mandatory nutrition labelling for alcoholic beverages, which the alcoholic beverages industry has so far sought to avoid (see Trade Perspectives, Issue No. 17 of 21 September 2018).
The ASA’s recent rulings in the UK show that alcoholic beverages manufacturers need to carefully consider their advertising, including on social media, and product labelling. Notably, alcoholic beverages may not be presented as a healthier option than not drinking. As regards calories, some alcoholic drinks are less calorific than others. Beverage manufacturers may provide consumers transparent factual information about the ingredients and the energy level in their beverages, as well as on the number of units in the bottle or a serving. However, economic operators must be aware of the relevant legal rules and must ensure that the labels, websites, and other marketing campaigns, including on social media, comply with the applicable rules, or risk actions by enforcement authorities, competitors, or consumer associations.
- Council Decision (EU) 2021/1157 of 30 June 2021 on the position to be taken on behalf of the Union in reaction to the unilateral declaration of the United Kingdom setting out the practice it intends to put in place as regards imports of meat products from Great Britain into Northern Ireland between 1 July and 30 September 2021
- Commission Implementing Regulation (EU) 2021/1165 of 15 July 2021 authorising certain products and substances for use in organic production and establishing their lists (1)
- Commission Implementing Decision (EU) 2021/1161 of 13 July 2021 amending Decision 2011/891/EU and Implementing Decisions (EU) 2017/1211, (EU) 2017/1212, (EU) 2017/2449, (EU) 2019/2085 and (EU) 2019/2086 as regards the authorisation holder and its representative in the Union for the placing on the market of products containing, consisting of, or produced from certain genetically modified organisms (notified under document C(2021) 5148) ( 1 )
- Commission Implementing Decision (EU) 2021/1137 of 30 June 2021 on the request for registration of the European citizens’ initiative entitled ‘European EcoScore’, pursuant to Regulation (EU) 2019/788 of the European Parliament and of the Council (notified under document C(2021) 4951)
Ignacio Carreño, Simone Dioguardi, Tobias Dolle, Alya Mahira, Lourdes Medina Perez, and Paolo R. Vergano contributed to this issue.
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