Australian wine businesses have been navigating a shifting regulatory landscape for some time, but the timeline just became concrete. Whether you operate a large winery in the Barossa, a boutique estate in McLaren Vale, or grow grapes in Margaret River or the Yarra Valley, the practical implications of this reform deserve your attention right now.

What Has Actually Been Confirmed

The Wine and Other Legislation Amendment Bill 2026 passed both Houses of Parliament on 10 September 2026 [1].

Support the implementation of a new mandatory Code of Conduct for Winegrape Purchases, to be administered by the Australian Competition and Consumer Commission (ACCC);
Enable Wine Australia to conduct or arrange surveys of the grape and wine industry; and [1]
Enable Wine Australia to use and disclose information for authorised purposes [1].

The mandatory Code itself is a separate instrument. The Department of Agriculture, Fisheries and Forestry (DAFF) has released an Exposure Draft of the mandatory Code of Conduct for Winegrape Purchases for consultation [1].

Important distinction: The introduction of a mandatory Code of Conduct for Winegrape Purchases was recommended by the 2025 review by Dr Craig Emerson and the Australian Government's response to that review, as well as the Rural and Regional Affairs and Transport References Committee's Australian winegrape purchases code of conduct inquiry and the Australian Government's response to that inquiry [1]. These are review recommendations and Government commitments. Whether and exactly how they appear in the final, gazetted Code will depend on the outcome of the Exposure Draft consultation process [1]. Do not treat Emerson review recommendations as confirmed regulatory text until the Code is formally made.

The Emerson Threshold: Does Your Winery Fall In?

The Emerson review and subsequent Government processes have driven the proposal to apply the Code to wineries above a certain purchase threshold. If your winery is a significant purchaser of winegrapes, you should be preparing now — even while the final threshold in the Code is yet to be confirmed.

For many mid-sized wineries — including those buying fruit from multiple Barossa or McLaren Vale growers — the Code may well capture your operations. Even if you currently sit below any threshold, growth in purchased tonnage over recent vintages could bring you within scope.

The practical first step is pulling together your grape-intake records for the past three seasons and calculating your rolling average. If your winery management system does not make that calculation straightforward, that is a gap worth addressing before the Code commences.

What the Code Is Likely to Require: Key Areas to Prepare

Based on the Emerson review recommendations and the Government's publicly stated intentions, the Code is expected to address the following areas. Again, treat these as the policy direction — not confirmed regulatory text:

Written Supply Agreements

All winegrape purchase agreements may need to be in writing, covering price, payment terms, and other key conditions. For wineries that have historically relied on informal or verbal arrangements with long-standing growers — common in tightly knit regions like the Yarra Valley — this represents a genuine change in contract management practice.

What to do now:

Audit your current supply agreements. Identify any that are verbal, informal, or poorly documented.
Begin drafting template written agreements with your legal adviser.
Build a contract register so you can track expiry dates, renewal obligations, and any variation history.

Price and Payment Term Reporting to Wine Australia

Offer prices and payment terms may need to be reported to Wine Australia. This introduces a new data obligation — one that sits alongside Wine Australia's expanded statutory power (confirmed in the Bill) to collect, use, and disclose industry information for authorised purposes.

What to do now:

Confirm that your accounting and procurement systems can generate the specific data fields likely to be required: price per tonne by variety and region, and payment timing.
Consider how you will extract and submit this information efficiently. If your grape-intake and payment records sit in disconnected spreadsheets, this is the time to centralise them.

Objective Quality Parameters for Deductions and Rejections

Any price deduction or grape rejection will need to rest on an objective, documented quality parameter. This is a significant discipline shift for wineries where rejection or downgrade decisions have been made at the weighbridge with minimal written justification.

What to do now:

Document your current quality assessment protocols at intake — Brix, pH, titratable acidity, visible contamination criteria, and any variety-specific standards.
Ensure those parameters are recorded against each lot at reception, not reconstructed after the fact.
Link your weighbridge records to your quality data so any deduction has an auditable trail.

Grape Intake Records, Contract Management, and Payment Tracking

The three practical systems that will matter most under the Code are:

Grape intake and lot traceability — you need to know exactly what came in, when, from which grower, at what weight, and with what quality data attached. This is the foundation of any defensible deduction or rejection record.
Contract management — a living register of all supply agreements, with version control and payment term visibility, is no longer optional.
Payment-term tracking — if payment terms must be reported and adhered to, you need a system that flags when a payment is due and records when it was made.

Cepaos covers grape reception, weighing, and lot traceability from vineyard to tank as part of its core harvest intake module, with quality analyses recorded per lot in the wine lab module. These are the data layers that will underpin compliance with objective-quality-parameter requirements. The cepaos API (a paid add-on) also allows connection to external accounting systems where payment-term tracking is managed.

The GI System and the Broader Regulatory Picture

Separately from the Code, DAFF is consulting on the most suitable option to protect wine Geographical Indications (GIs) in the context of the Australia–European Union Free Trade Agreement and a new Wine Agreement. Written submissions on that process closed 30 September 2026 and were directed to winepolicy@aff.gov.au [1].

Wine Australia is also conducting an independent review of the Wine Australia Regulations 2018, examining whether they remain fit for purpose ahead of their scheduled sunset in 2028 [1].

These are three distinct but overlapping regulatory processes. The Code of Conduct timeline is the most urgent, but wineries with significant export business — particularly those relying on recognised GIs like Barossa Valley, McLaren Vale, or Margaret River — should monitor the GI consultation outcomes closely.

What Growers Should Be Doing

If you are a winegrape grower selling to a winery that is likely to be captured by the Code, the reforms are designed to strengthen your position. Written agreements, transparent pricing, and objective quality standards all benefit the supply side of the relationship.

Practically, growers should:

Keep records of all current supply arrangements and any verbal price commitments.
Understand the quality parameters your winery uses for assessment, and ask for them in writing as part of any new agreement.

Next Steps Before the Code Takes Effect

The timeline is tight. The Bill has passed both Houses of Parliament and the Code's Exposure Draft consultation closes 9 October. Here is a practical checklist:

[ ] Assess your purchased tonnage to determine whether you are likely to fall within scope.
[ ] Audit all current supply agreements for written documentation gaps.
[ ] Review your grape intake and quality recording processes against the likely objective-parameter requirement.
[ ] Confirm your accounting system can report payment terms by grower and lot.
[ ] Monitor DAFF and Wine Australia communications for the finalised Code.
[ ] Seek legal advice on your standard supply agreement template.

The regulatory direction is clear. The time to prepare is now — not after the Code is formally gazetted.

Cepaos is winery management software built to support harvest intake traceability, lot-level quality records, and regulatory compliance workflows. To see how it can help your winery prepare for the new Code, visit cepaos.com.

Sources

Wine legislation and regulation: what’s changing and how to take part — wineaustralia.com, published 37 days ago. https://www.wineaustralia.com/news/articles/wine-legislation-and-regulation-whats-changing-and-how-to-take-part