Comments from EU relating to Draft Technical regulation on alcoholic products safety.

Labeling requirements.

The EU has the following concerns regarding labeling provisions: The EU is of the opinion that the indication of the mass concentration of sugars for wines (Article 6.16 sub 6) should not be required since there is no such requirement at international level. The EU considers that the indication of the month and the year of tirage for collection sparkling wines and high quality collection sparkling wines (Article 6.16 sub 9) should not be required as it brings no added value to the consumer and could be misleading. Instead, the vintage year should be indicated. The indication of the date of bottling is irrelevant for some products such as sparkling wines. Therefore the EU would like to suggest to Russia that only the production date is mentioned in order to avoid misleading consumers (Article 6.16 sub 13).The indication of the storage conditions is unnecessary for products containing more than 10% by volume of alcohol (Article 6.16 sub 14).With regard to the size of the health warning (which must cover 20% of the label) the EU would like to receive clarification as regards the reasons for setting out this requirement and, in particular whether more feasible size requirements have beenconsidered.7 In this respect, the EU would like to recall Article 2.2 of the TBT Agreement, which states that: "Members shall ensure that technical regulations are not prepared, adopted or applied with a view to or with the effect of creating unnecessary obstacles to international trade". The EU would like to receive clarification of what is meant by "the indication of the document in compliance with which the alcoholic beverage is produced" as this is unclear. In any case, this requirement does not seem to have any equivalent in the international practice (Article 6.16 sub 17).The requirement that the information on the label should be provided in Russian and in the languages of the other members of the Customs Union is excessive and unjustified (Article 6.21).

Notification procedures

The EU would like to express its concerns regarding the procedure of notification of alcoholic products (Article 3). The rules on the notification of the release of alcoholic beverages on the market are bound to represent a heavy burden on economic operators. The information that is required to be provided would also be duplicative of other information that is already provided to the Russian authorities through other procedures such as the State Registration, the Declaration of Compliance, the UFAIS system managing excise stamps and the Customs Clearance. The EU is also concerned that such a procedure would amount to a priorauthorisation for the release of the product on the market since the circulation of alcoholic beverages in Russia and in the other members of the Customs Union will only be allowed after reception by the "notifying party" of confirmation of reception of the notification by the authorized body of Russia and the other members of the Customs Union. For these reasons, the notification procedure foreseen by the draft may constitute an unnecessary obstacle to international trade in breach of Article 2.2 of the TBT Agreement. Therefore, the EU would like to request the withdrawal of the notification measure from the draft regulation as an unnecessary barrier to trade.


Certification procedures

The EU would like to receive confirmation that the procedures of production control and conformity assessment will not be applicable to EU production sites; that the Accompanying document will be considered as sufficient to establish the compliance of EU products with the notified technical regulation given that EU production rules are generally in line with the requirements of that regulation and that therefore nothing will oppose the marking of those products with the Customs Union's single product mark. The EU believes that an explicit statement should be introduced in the notified draft technical regulation to ensure that these inspections are limited to the territory of Russia and the other members of the Customs Union only and that, for imported  products, the production control already operated and the certificates issued by local authorities are accepted as equivalent. In this respect, the EU would like to recall Article 6.1. of the TBT Agreement which states that "Without prejudice to the provisions of paragraphs 3 and 4, Members shall ensure, whenever possible, that results of conformity assessment procedures in other Members are accepted, even when those procedures differ from their own, provided they are satisfied that those procedures offer an assurance of conformity with applicable technical regulations or standards equivalent to their own procedures".

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