There is a misleading way to read wine export regulations: as a disconnected collection of national procedures. The EU VI-1, the US COLA, the Chinese GACC registration — each with its own form, its own timeline, its own bureaucratic folklore.
There is a more useful way: to understand that every market is asking the same questions — who are you, where did this wine come from, and what exactly does it contain — and that what varies is only the format of the question. Read that way, the 2026 regulatory picture tells a clear story: the questions are going electronic, and competitive advantage is shifting toward wineries that can answer them with data rather than folders.
This is the destination-market panorama, with sources.
European Union: the most demanding market, the best documented
For wine entering the EU from third countries, the central instrument remains the VI-1 document: a certificate and analysis report issued by authorities and laboratories designated by the exporting country, under Commission Delegated Regulation (EU) 2018/273. The European Commission maintains the list of competent authorities and authorised producers notified by each third country; some trading partners benefit from simplified self-certification regimes negotiated under bilateral agreements.
For wine that circulates within the EU under excise duty suspension, paper disappeared years ago: the electronic administrative document (e-AD) travels through EMCS, and any exporter still managing movements with ring binders notices it at every consignment.
On top of this sits the consumer information layer: since the 2023 harvest, Regulation (EU) 2021/2117 requires nutritional declaration and ingredient listing — fulfillable via an e-label QR code — for wine marketed in the EU. In practice this adds another documentary requirement to the dossier for every label exported to Europe (full e-label guide here).
The practical tool for checking current requirements from the EU side is Access2Markets maintained by the European Commission.
United Kingdom: the post-Brexit simplification that favours the exporter
The UK made the most-discussed regulatory move of the decade in this space: the elimination of the VI-1 certificate for wine imports into Great Britain, effective 1 January 2022. The official reference is GOV.UK's importing and exporting wine guidance.
The strategic reading matters more than the saved paperwork: London chose to compete by reducing documentary friction relative to Brussels. For an exporting winery, Great Britain is today one of the large markets with the lowest certificatory burden at the border — which does not eliminate GB-specific labelling obligations (a UK Food Business Operator address on the label, UK-specific allergen wording) or the importer's excise duty liabilities, but it does shorten the export dossier significantly.
Note that Northern Ireland follows different rules from Great Britain under the Windsor Framework and continues to apply EU wine rules for goods entering the EU single market.
United States: minimal certification, maximum system
The US asks almost nothing in the way of European-style certificates. What it asks instead is fit within its system:
- Wine can only enter through an importer holding a Basic Permit from the TTB, and every label needs a COLA (Certificate of Label Approval) — the registry is at ttb.gov/wine.
- The exporting winery must be registered with the FDA as a foreign food facility, and every shipment requires prior notice (FDA prior notice for imported food) before arrival at a US port.
- For most origins, no systematic analysis certificate is required at customs, though US importers routinely request one contractually.
- State-level distribution permits (three-tier system) apply once the wine clears federal entry; requirements differ by state.
The practical consequence: in the US the bottleneck is not obtaining a certificate but the coherence of data between winery, importer, and label. A COLA approved on one alcohol level that later diverges from the lot's laboratory analysis is a classic problem — and an avoidable one.
Australia: import approval before the shipment
Wine Australia administers the import register under the Australian Grape and Wine Authority Act 2013. Before any consignment of imported wine enters Australia, the product must be registered and approved:
- The importer or overseas producer registers the wine product in the Wine Australia Import Register, providing product details including alcohol content, sulphite levels, and allergen declarations.
- Wine Australia verifies compliance with the Australia New Zealand Food Standards Code (FSANZ), particularly composition and labelling rules.
- Once approved, individual consignments require import entry with the Australian Border Force (ABF), plus applicable duties and goods and services tax (GST).
For full importation requirements, the authoritative source is Wine Australia's importer guidance.
New Zealand: MPI import health standards
New Zealand applies a straightforward documentary regime compared to some markets. The Ministry for Primary Industries (MPI) requires:
- Import health standards compliance — wine must meet the New Zealand Food Standards Code (shared with Australia under FSANZ).
- A commercial invoice and packing list accompany each consignment.
- MPI border inspections are risk-based; consignments may be sampled.
- Wine labels must comply with New Zealand Food Safety requirements: alcohol by volume, country of origin, allergens (sulphites), and a New Zealand importer address.
No VI-1 equivalent is required. The importer is the primary compliance holder. NZ Trade and Enterprise publishes practical export to New Zealand guides for key product categories.
South Africa: SAWIS and the Wine of Origin system
South Africa requires wine exported under the Wine of Origin (WO) designation to be certified through SAWIS (South African Wine Industry Information and Systems). Each certified consignment is issued a SAWIS certificate of compliance. For uncertified wine (table wine without WO designation), the administrative burden is lighter but traceability records still form the backbone of any export audit.
On the importing end, South African wine entering third-country markets follows the destination's requirements (EU VI-1 for EU, TTB COLA for US, etc.) rather than a symmetric SA-specific import requirement.
Canada: provincial monopolies as de facto regulators
Canadian market access passes through provincial liquor monopolies — the LCBO in Ontario, the SAQ in Quebec, the BC Liquor Distribution Branch in British Columbia — that act as additional commercial regulators over and above federal customs:
- Each board requires product registration with tasting samples, technical analysis, and compliance with Health Canada labelling rules.
- Lead times from application to listing can run 6–18 months depending on the province and category.
- The Canada Border Services Agency (CBSA) handles federal customs; duties apply under CETA (for EU wines) or standard rates for non-preferential origins.
The consequence: for wineries targeting Canada, the provincial listing process is usually the longer and more demanding track, not customs clearance itself.
China: the establishment as the unit of trust
China shifted control upstream: since 2022, foreign food producers — wineries included — must be registered with GACC (General Administration of Customs of China) under Decree No. 248 (2021) before exporting. The GACC registration number accompanies the product and the importing establishment.
Beyond registration, wine shipments require: certificate of origin (preferably under a preferential trade agreement where applicable), analysis report, Chinese-language labelling conforming to GB 15037 and GB/T 15038 standards, and phytosanitary and health certificates where applicable.
The pattern China introduced is the one worth retaining: the market no longer evaluates shipments, it evaluates establishments. A winery either enters or does not as a registered entity, with its compliance history attached.
The thesis: export documentation is becoming a data query
Placed in sequence, the moves major markets are making all point in the same direction:
- From paper to structured data. e-AD via EMCS, electronic customs windows, online establishment registries. The physical certificate signed and stamped recedes year by year.
- From shipment to establishment. China with GACC, the EU with its lists of authorised third-country producers: the unit of trust is no longer the consignment, it is the winery and its record.
- From certification to coherence. Where entry certification falls away (UK), operator responsibility rises: if something goes wrong, the authority reconstructs the chain backwards — and expects you to be able to do the same.
The three trends converge on an uncomfortable conclusion for any winery managing traceability in spreadsheets: the 2026 export dossier is not drafted, it is queried. Grape origin, lot analysis, winery movement records, bottled volumes by label — if those data exist in structured, linked form, the dossier for any destination is an export. If they do not, every new market is a weeks-long documentary archaeology project.
That is, in the end, the reason Cepaos is built around a single traceability record from which declarations and documents are derived — for the domestic market and for export alike. Not because software signs certificates — it does not — but because the winery with its data in order can answer any regulator, in any format, in the time an active shipment window allows.
You can estimate your cost exposure for any target market with the wine export cost simulator.