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FAQ – Frequently Asked Questions about Wine Standards Management Programmes

November 2008

What do I do if there is no verifier in my region?

If a winemaker is unable to confirm a verifier for their region please contact Lisa Winthrop on 04 894 2663, lisa.winthrop@nzfsa.govt.nz.

What happens if I don’t register a wine standards management plan?

Unless subject to an exemption, all winemakers must be operating a registered wine standards management plan by 1 December 2008. Winemakers who do not register a wine standards management plan may be subject to sanctions under the Wine Act 2003.

Additionally, grape wine made after 1 December 2008 will not be eligible for export unless it is made in a winery that has a wine standards management plan. This means that winemakers who don’t register a wine standards management plan will not be able to export grape wine made in vintage 2009 or onwards.

There are three exemptions from the requirement to operate a wine standards management plan:

1. Winemakers who only affix labels to packaged wine;

2. Very small winemakers;

3. Specified, individual winemakers who make other beverages in addition to making wine.

If I make wine for other people, do I need a multi-business WSMP?

No. Where a winemaker is making wine for other people (i.e. making wine on contract), all the wine made at that winery is covered by the WSMP for that winery.

A multi-business WSMP is used where more than one physical premises wants to register under one WSMP.

I share a winery with another winemaker, who is responsible for the wine standards management plan?

There are three options for this situation:

• One winemaker takes responsibility for the WSMP for that premises;

• The responsibility for the WSMP is shared by the persons who use the winery;

• Each winemaker who uses the premises has their own WSMP.

Whatever decision is made, all parties need to be clear on the decision and the responsibilities; winemakers may decide to clarify these by using contracts or agreements.

Where several winemakers are making wine under a single WSMP, all records and relevant documents must be available to the verifier.

I share a winery with another winemaker, am I still eligible for the small winemaker exemption?

If less than 10,000L wine per year is processed through the winery and all the wine is sold in NZ then the winemakers using that facility will be eligible for the exemption.

If more than 10,000L wine per year is processed through that winery, then that winery must be subject to a registered WSMP, and all wine processed through the winery must meet the WMSP requirements. This means that one winemaker needs to register a WSMP for that winery.

What are the requirements when unfinished wine is stored at a contract storage facility?

The winemaker (or person who is in charge of the WSMP) is responsible for ensuring that wine is stored in accordance with the WSMP requirements.

If wine is stored off-site, the winemaker must ensure that the wine continues to meet the WSMP requirements at all times (e.g. traceability records are maintained). The winemaker must also ensure that the storage facility meets the WSMP requirements.

I am fermenting wine at a site away from my winery; do I need a site plan for this?

When wine is fermented at a site that is not a winery (e.g. barrel fermenting in a contract storage facility), a site plan for both sites should be submitted with the WSMP registration documents. The winemaker needs to ensure that all wine meets the WSMP requirements at all times. The winemaker must also ensure that both sites meet the WSMP requirements.

Where wine is being made by another winery on contract, you do not need a site plan for the contract winery as this will be covered by their own WSMP.

Do contract winemakers need to obtain and retain spray diary information about the grapes of their clients?

Making wine on contract is a different situation from winemakers who make wine for themselves. In contracting situations, it may not be practicable or desirable for the contract winemaker to have copies of spray diaries.

Grape growers are required to supply grapes that are suitable for making into wine. If a spray diary is not provided with the grapes, an acceptable alternative would be for the grape supplier to make a declaration about each block of grapes. Ideally, the declaration would include something similar to the following:

''All agrichemical pre-harvest intervals have been met and agrichemicals have been applied in accordance with the [year] export spray schedule. Any departures are noted below:''

What are the requirements for water used during winemaking?

Winemakers need to ensure that all water used during winemaking and for cleaning and sanitation is ‘clean water’.

Town supply, and water supplied by a third party that is shown to meet requirements of the Health Act 1956, is considered to be 'clean water'. Winemakers using these water sources do not need to do anything further.

Winemakers who use their own water supply (e.g. tank water, bore water, river water) must have their water tested annually (samples should be taken at the point of use) to demonstrate it meets the clean water criteria. Clean water has two criteria:

• E.coli <1 in 100mL of sample

• Turbidity must not exceed 5 NTU

Tests for E. coli must be performed at a laboratory that is:

• accredited in accordance with ISO 17025; or

• recognised by the Ministry of Health - view the list of laboratories at: http://www.drinkingwater.org.nz/mohlabs/labsfordetbyregion.asp?detcode=ALL; or

• otherwise approved by the Director-General, e.g. Animal Products, Laboratory Approval Scheme: http://www.nzfsa.govt.nz/animalproducts/registers-lists/milab/index.htm; or

• Dairy, Register of Approved Recognised Agencies: http://www.nzfsa.govt.nz/dairy/registers-lists/reg-lab.htm

Can a group of winemakers collectively engage a verifier and schedule all their verifications in one visit?

Yes, winemakers can group together and schedule their verifications to occur in the one visit to reduce the travel component of the verification cost.

In this situation, winemakers will need to consider the best time to have their verifications. NZFSA would prefer that winemakers keep within their 12 month verification cycle wherever possible. This means that if a group of winemakers would like to be verified at around the same time, they should schedule verification to occur at the time of the earliest due date, i.e. if there is a spread from May to August, the verification should be scheduled for May. However, if a group of winemakers approached NZFSA with a proposal (and adequate justification), NZFSA may be flexible around the verification timing.

What records are required when bulk wine is purchased?

All wine must be traceable from the package to the vineyard and vice versa, including all bulk wine that is used in blends. See section 5 of the NZ Winegrowers wine standards management plan Code of Practice for details on records that must be kept for bulk wine.

What does a winemaker need to do if they change their verifier?

The winemaker must notify NZFSA in writing as soon as practical after engaging a new verifier. You need to include a letter of confirmation from your new verifier.

When do I have to have my first WSMP verification?

Winemakers who have previously been subject to grape wine export record keeping audits remain on their 12 month verification cycle. This means that if their 2008 export record keeping audit occurred in July, their first WSMP verification needs to occur by July 2009.

All other winemakers must have their first WSMP verification within six month of their WSMP registration date.

Will the grape wine export record keeping audits still be required?

Export record keeping audits will not continue after 2008 as all the record keeping requirements are now part of the WSMP requirements. There may be export requirements that verifiers will check. These will be notified when they are finalised.

Will the local council still inspect my winery?

No, not in relation to the Food Hygiene Regulations. However if you have a café, restaurant or similar you are still subject to the Food Hygiene Regulations. Wineries are also subject to other local Council requirements such as winery waste, sale of liquor, building consents etc.

What does GMP mean in relation to additives?

The permissions for food additives are in Part 1.3 of the Food Standards Codes. Additives are permitted for specified technological functions. The maximum amount of an additive permitted in the final product is either a set limit (e.g. sulphur dioxide) or set at GMP (Good Manufacturing Practice).

Where the limit is set at GMP, the amount of additive in the final product should reflect the lowest amount necessary to achieve the technological function for which it is permitted.

If a winemaker has their wine bottled by another winery, who is required to have the wine standards management plan for bottling?

The facility that bottles the wine will have a wine standards management plan for that activity. This does not need to be covered by the winemaker’s wine standards management plan.

Each wine standards management plan will be verified by the verifier contracted to verify that particular plan. The winemaker will need to record the WSMP number of the bottling facility plant for traceability purposes.

For further information, contact:

Lisa Winthrop
Programme Manager (Wine & Plant Products)
New Zealand Standards Group
Ph: 04 894 2663
Email: lisa.winthrop@nzfsa.govt.nz