How to comply with EU CMO wine regulations in Croatia
What the EU Common Market Organisation for wine requires from a Croatian producer and where each part lives in Cepaos.
What is the EU CMO for wine
The Common Market Organisation (CMO) under EU Regulation 1308/2013 sets common rules for wine production, labelling and trade across the EU, including Croatia. EU Regulations 2018/273 and 2018/274 add the vineyard register, the harvest, production and stock declarations, the accompanying documents and the cellar registers. In Croatia these are filed with the Paying Agency (APPRRR) in AGRONET under the Pravilnik o vinarstvu (NN 81/2022).
Prerequisites
- Vineyard parcels in Vineyards > Parcels & cadastre > Cadastre (
/cuarteles/catastro), each with its ARKOD ID (HR) in the Cadastral data section of the parcel form. - Cellar book kept in Knjiga podruma (HAPIH) (
/bodega/knjiga-podruma).
Step by step
1. Open the EU CMO page
In the sidebar, under Compliance, open EU traceability (CMO) (route /compliance/hr-eu-cmo). The page summarises the obligations and their deadlines:
| Obligation | Authority | Deadline |
|---|---|---|
| Vineyard Register | APPRRR | — |
| Harvest Declaration | APPRRR | 15 January |
| Production Declaration | APPRRR | 15 January |
| Stock Declaration (stock as at 31 July) | APPRRR | 10 September |
It also lists the data the vineyard register needs per parcel.
2. Keep the ARKOD ID of each parcel
Producers in sub-categories A1 and A2 must have their production areas recorded in ARKOD, the APPRRR record of agricultural land use (Pravilnik o vinarstvu, art. 4(3)). Enter the ID of each vineyard in the parcel form of the cadastre (steps in the article «How to prepare the Croatian vineyard register and declarations (APPRRR) in Cepaos»). Cepaos stores it as you typed it, because the official format is not published.
3. Cellar registers
Every entry and exit of products must be written in the cellar registers within two days of receipt or delivery, and the registers are closed every year on 31 July (Pravilnik o vinarstvu, art. 11). Record your operations in Knjiga podruma (HAPIH).
4. Declarations
The harvest, production and stock support documents are downloaded as PDF in APPRRR declarations (/compliance/hr-apprrr). You file the declarations yourself in AGRONET.
5. Excise movements (e-AD)
On the same EU CMO page, the e-AD / EMCS section generates a draft electronic administrative document (IE815 message) for wine moved under duty suspension. Still and sparkling wine are taxed at 0.00 EUR per hectolitre (Uredba NN 156/2022, art. 5), but movements under suspension still need an e-AD. Sending it to the Customs Administration requires your own gateway credentials; until Customs accepts it, the draft has no binding ARC.
6. Labelling
Since 8 December 2023 wine labels must include the list of ingredients and the nutrition declaration; both can be given through a QR code, but the energy value and allergens must stay on the physical label. Mandatory information must be in Croatian and in the Latin alphabet. Cepaos creates the public e-label page behind the QR code in E-labels (/elabel).
Frequently asked questions
Does CMO compliance replace Croatian national requirements?
No. The CMO sets the EU baseline; Croatian law (Zakon o vinu and the Pravilnik o vinarstvu, NN 81/2022) adds national rules such as the AGRONET declarations.
Where can I check the sources?
The Croatian winemaker library at www.cepaos.com/hr-HR/biblioteca/hr lists each deadline, rate and rule with its legal basis, the official source and the date it was verified.
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