EN   EN 
 
 
 EUROPEAN  
COMMISSION   
Brussels, XXX   
[…](2021) XXX  draft  
 
COMMISSION NOTICE  
Guidelines for the implementation of certain labelling provisions of Regulation (EU) 
2019/787 of the European Parliament and of the Council of 17 April 2019 on the 
definition, description, presentation and labelling of spirit drinks, the use of the names 
of spirit drinks in the presentation and labelling of other foodstuffs, the protection of 
geographical indications for spirit drinks, the use of ethyl alcohol and distillates of 
agricultural origin in alcoholic beverages, and repealing Regulation (EC) No 11 0/2008    
   
COMMISSION NOTICE  
Guidelines for the implementation of certain labelling provisions of Regulation 
(EU) 2019/787 of the European Parliament and of the Council of 17 April 2019 
on the definition, description, presentation and labelling of spirit drinks, the use 
of the names of spirit drinks in the presentation and labelling of other 
foodstuffs, the protection of geographical indications for spirit dri nks, the use 
of ethyl alcohol and distillates of agricultural origin in alcoholic beverages, and 
repealing Regulation (EC) No 110/2008  
  
  
Foreword  and disclaimer  
 
The new Spirit Drinks Regulation (EU) 2019/787 was published on 17 May 2019 
and entered into force 7 days later. However, it only appl ies from 25 May 2021 with 
respect to most of its production and labelling provisions.  
In line with Article 43(2) of Regulation (EU) 2019/787, the purpose of the present 
guideline document – which is also applicable as of 25 May 2021 – is to ensure its 
uniform application for the benefit both of national administrations and food 
business ope rators (e.g. spirit drinks producers  and importers)  as concerns certain 
labelling provisions laid down therein.  
It is limited to the practical explanation of labelling provisions applicable to spirit 
drinks, in particular concerning the use of ‘legal names ’, ‘compound terms’ , 
‘allusions’, ‘mixtures’ and ‘blends’.  
To this end, it gives several non -exhaustive examples that are provided for 
illustration purposes only.  
 
The present guideline document  is provided for information purposes only and its 
contents are not intended to replace consultation of any applicable legal sources or 
the necessary advice of a legal expert, where appropriate.  
Neither the Commission nor any person acting on its behalf can be held responsible 
for the use made of these guidance no tes nor can they be considered as a binding 
interpretation of the legislation.  
This document is intended to assist businesses and national authorities in the 
application of the Spirit Drinks legislation. Only the Court of Justice of the 
European Union is competent to authoritatively interpret Union law .  
 
 
References to legal provisions indicated hereinafter are intended as being referred 
to Regulation (EU) 2019/787  (‘SDR’) , save otherwise explicitly indicated.  
 
  General Labelling Rules for Spirit Drinks  
3 Table of Contents  
1. GENERAL LABELLING RU LES FOR SPIRIT DRINK S ................................ ........ 5 
1.1. Horizontal provisions (FIC Regulation)  ................................ ............................ 5 
1.2. Principles governing the Spirit Drinks Regulation  ................................ ............ 6 
1.3. Legal names  ................................ ................................ ................................ .......6 
1.4. Terms that may supplement legal names  ................................ ........................... 9 
1.5. Voluntary food information (FIC Regulation)  ................................ ................. 12 
1.5.1.  Name of a foodstuff used in the production  ................................ .......14 
1.6. Ethyl alcohol’s or distillates’ raw materials  ................................ ..................... 15 
1.7. Plant raw materials used as legal names  ................................ .......................... 17 
2. COMPOUND TERMS  ................................ ................................ .............................. 19 
2.1. What is a compound term  ................................ ................................ ................ 19 
2.2. Conditions of use  ................................ ................................ ............................. 21 
2.3. Labelling provisions  ................................ ................................ ......................... 23 
2.4. Checks  ................................ ................................ ................................ .............. 24 
3. ALLUSIONS  ................................ ................................ ................................ ............. 26 
3.1. What is an allusion  ................................ ................................ ........................... 26 
3.2. Conditions of use and labelling provisions  ................................ ...................... 26 
3.2.1.  Allusions on foodstuffs other than alcoholic beverages  .................... 28 
3.2.2.  Allusions on alcoholic beverages other than spirit drinks  ................. 29 
3.2.3.  Allusions on liqueurs  ................................ ................................ ......... 31 
3.2.4.  Allusions on spirit drinks other than liqueurs  ................................ ....33 
3.2.5.  Other labelling rules for allusions  ................................ ...................... 38 
3.3. Allusion to ‘imitation’ spirit drinks flavourings  ................................ .............. 40 
3.4. Low/zero -alcohol beverages referring to spirit drinks’ names  ........................ 42 
3.5. Checks  ................................ ................................ ................................ .............. 44 
3.5.1.  On foodstuffs other thank alcoholic beverages  ................................ ..44 
3.5.2.  On alcoholic beverages other than spirit drinks  ................................ .44 
3.5.3.  On liqueurs  ................................ ................................ ......................... 45 
3.5.4.  On spirit drinks other than liqueurs ................................ .................... 46 
3.5.5.  On ‘imitation’ flavourings  ................................ ................................ .48 
3.5.6.  Allusions to GIs  ................................ ................................ ................. 48 
4. MIXTURES  ................................ ................................ ................................ ............... 50 
4.1. What are mixtures  ................................ ................................ ............................ 50 
4.2. Conditions of use and labelling provisions  ................................ ...................... 51 
4.2.1.  General rules  ................................ ................................ ...................... 51 
4.2.2.  Mixtures corresponding to a spirit drink category  ............................. 52 
4.3. Checks  ................................ ................................ ................................ .............. 53 
5. BLENDS  ................................ ................................ ................................ .................... 55 
5.1. What are blends  ................................ ................................ ................................ 55 
5.2. Conditions of use and labelling provisions  ................................ ...................... 56 
5.3. Checks  ................................ ................................ ................................ .............. 57 
6. OVERVIEW TABLES  ................................ ................................ .............................. 58 
6.1. Compound Terms (CT)  ................................ ................................ .................... 58 
6.2. Allusions  ................................ ................................ ................................ .......... 59 
6.3. Mixtures  ................................ ................................ ................................ ........... 60 
6.4. Blends  ................................ ................................ ................................ .............. 60 
 General Labelling Rules for Spirit Drinks  
4 Table of Symbols and Abbreviations  
 
ABV  Alcohol by volume  
CT Compound term  
EAAO  Ethyl alcohol of agricultural origin  
FIC (Regulation)  Regulation (EU) No 1169/2011 on food information to  
consumers  
GI Geographical Indication  
QUID  Quantitative indication of  ingredients  
SDR  Regulation (EU) 2019/787 (Spirit Drinks Regulation)  
§ Paragraph of the present Guidelines  
# Example box number of the present Guidelines  
 
  General Labelling Rules for Spirit Drinks  
5 1.  GENERAL LABELLING RULES FOR SPIRIT DRINKS  
Article 3 , points (1), (4)  and (8) Definitions  
Article 4 , points (1), (2), (3) and 
(4) Technical definitions and requirements  
Article s 9, 10 and 13 Legal names and other l abelling 
provisions  
1.1. Horizontal provisions (FIC Regulation)  
According to Article 9 of Regulation (EU) 2019/7871 (‘SDR’) , ‘spirit drinks 
placed on the Union market shall comply with the presentation and labelling 
requirements set out in Regulation (EU) No 1169/20112, unless otherwise 
provided for in this Regulation’3. 
Except for explicit provision of lex specialis  as set out in the SDR, the 
presentation and labelling rules laid down for any foodstuff by Regulation 
(EU) No 1169/2011  (‘FIC Regulation ’) are thus also of application for spirit 
drinks  as such and when present in fo odstuffs . 
Among the key principles that are set out in the horizontal EU food labelling 
legislation ( FIC Regulation) that are also of paramount importance also for 
spirit drinks, is that food information shall not be misleading but shall be 
accurate, clear  and easy to understand for consumer s4. 
Information to consumers  must be accurate , non-misleading  
and easy to understand . 
In this context, it is worthwhile reminding that the mandatory quantitative 
indication of certain (categories of) ingredients according to Article 9(1) , point 
(d), of the FIC Regulation – read in conjunction with Article 22 and Annex 
VIII of that Regulation  – is also among the horizontal rul es applicable to spirit 
drinks.  
                                                 
1  Regulation (EU) 2019/787 of the European Parliament and of the Council of 17 April 2019 on 
the definition, description, presentation and labelling of spirit drinks, the use of the names of 
spirit drinks in the presentation and labelling of other foodstuffs, the protection of geographical 
indications for spirit drinks, the use  of ethyl alcohol and distillates of agricultural origin in 
alcoholic beverages, and repealing Regulation (EC) No 110/2008 (OJ L 130, 17.5.2019, p. 1).  
2  Regulation (EU) No 1169/2011 of the European Parliament and of the Council of 25 October 
2011 on the provision of food information to consumers, amending Regulations (EC) No 
1924/2006 and (EC) No 1925/2006 of the European Parliament and of the Council, and repealing 
Commission Directive 87/250/EEC, Council Directive 90/496/EEC, Commission Directive 
1999/1 0/EC, Directive 2000/13/EC of the European Parliament and of the Council, Commission 
Directives 2002/67/EC and 2008/5/EC and Commission Regulation (EC) No 608/2004 (OJ L 
304, 22.11.2011, p. 1 8). 
3  This was already the case with Regulation (EC) No 110/2008, which refers in a number of 
labelling provisions to the horizontal rules of Directive 2000/13/EC that was repealed and 
replaced by the FIC Regulation as from 13 December 2014.  
4  See Article 7 of the FIC Regulation.  General Labelling Rules for Spirit Drinks  
6 QUID rules apply to spirit drinks  as provided for by the F IC Regulation 
as the SDR  does not explicit ly derogat e from them.  
1.2. Principles  governing the Spirit Drinks Regulation  
In line with the tradition set out by Council Regulation (EEC) No 1576/895 
and carried on with Regulation (EC) No 110/20086, Regulation (EU) 2019/787 
continues relying upon the same liberal principle : 
Every spirit drink may be placed on the EU market  as long as it is 
produced in line with general food law and is correctly labelled.  
In other words, no spirit drink  – as any oth er foodstuff – is banned from the 
EU market  as long as it complies with the provided requirements for its 
production, is safe for consumption and bears adequate consumer’s 
information.  
However, concerning spirit drinks, this liberal principle must coexist with the 
enhanced protection  EU law bestows upon  their legal names , which are 
either names reserved for  defined  categories  or for geographical indications . 
Legal names of spirit drink s (categories and GIs) are 
granted special protection . 
Indeed, in order to safeguard the reputation of spirit drink categories and GIs 
and to prevent the deception  of consumers , the SDR protects clearly defined 
products against illegitimate use in the presentation of derived products that do 
not meet  the stric t production criteria  applicable . 
Accordingly, food business operators (e.g. producer s, importer s) will have to 
carefully consider the labelling provisions set out in the SDR before placing 
on the EU market any spirit drink or f ood referring to spirit drin ks. 
Particular attention needs to be paid to rules on legal names (Article 10), 
compound terms (Article 11), allusions (Article 12) and other labelling 
provisions, including on mixtures and blends (Article 13).  
1.3. Legal names  
EU food law does not provide for mandatory product definitions except in 
cases of vertical EU legislation such as the SDR.  
Both Council  Regulation  (EEC) No 1576/89 and Regulation (EC) No 
110/2008 provided for an enhanced protection both of sales denominations 
                                                 
5  Council  Regulation  (EEC) No  1576/89 of 29 May 1989 laying down general rules on the 
definition, description and presentation of spirit drinks (OJ L 160, 12.6.1989, p. 1) . 
6  Regulation (EC ) No 110/2008 of the European Parliament and of the Council of 15  January  2008 
on the definitio n, description, presentation, labelling and the protection of geographical 
indications of spirit drinks and repealing Council Regulation (EEC ) No 1576/89 ( OJ L 39, 
13.2.2008, p. 16).  General Labelling Rules for Spirit Drinks  
7 and geographical indications,  imposing that every spirit drink marketed in the 
EU shall bear a clearly defined name.  
The present SDR  retains the same approach.  
Moreover, in order to align it to the wording of the FIC Regulation on food 
information to consumers, the legislator decided to replace the term ‘sales 
denomination’ with the term ‘legal name’, which is defined by:  
- Article 2(2) , point (n), of the FIC Regulation as ‘ the name  of a food 
prescribed in the Union provisions applicable to it’ […] ; and  
- Article 3 , point (1), of the SDR as ‘the name under which a spirit drink is 
placed on the market ’. 
Furthermore, according to Article 17(1) of the FIC Regulation ‘ the name  of the 
food shall be its legal name . In the absence of such a name, the name of the 
food shall be its customary name, or, if there is no customary name or the 
customary name is not used, a descriptive name of the food shall be provided ’. 
Paragraph 4 of the same provision specifies that ‘ the name of the food shall 
not be replaced with a name protected as intellectual prope rty7, brand name 
or fancy name ’. 
Finally, in compliance with Article 13(1) of the FIC Regulation, the legal 
name of spirit drinks, as any other mandatory food information, ‘ shall be 
marked in a conspicuous place in such a way as to be easily visible, clear ly 
legible and, where appropriate, indelible . It shall not in any way  be hidden, 
obscured, detracted from or interrupted  by any other written or pictorial 
matter or any other intervening material ’. 
Moving back to the specific provisions of the SDR, Article  10 provides for the 
following legal names to be used in the description, presentation and labelling 
of a spirit drink:  
a) MANDATORY : 
Article 10( 2): the name of the category  of spirit drinks whose requirements it 
complies with (or any other legal name permitted by that category);  
If a beverage  complies with all requirements laid down for a spirit 
drink category , it must bear the corresponding legal name . 
Article 10( 3): the l egal name ‘ spirit drink ’, if it does not comply with the 
requirements of any of the categories of spirit drinks set out in Annex I, but 
still complies with the definition of and requirements for spirit drinks laid 
down in Article 2;  
If a beverage  does not comply with the requirements of a ny spirit 
drink category, but corresponds to the general definition of a 
spirit drink, it must bear the generic name ‘spirit drink’ . 
b) FACULTATIVE : 
                                                 
7  According to Article 10(5), point (a), of the SDR , the legal name of a  spirit drink may be 
supplemented or replaced by a spirit drink GI . General Labelling Rules for Spirit Drinks  
8 Article 10( 4): legal name s permitted under  one or more categor ies of spirit 
drinks, if it complies with the requirements for more than one categories of 
spirit drinks set out in Annex I;  
#01 - Examples  of permitted labelling : 
1) A Brandy may also be placed on the market as a  wine spirit  if it complies with both the 
requirements for categories 4 and 5 of Annex I  
2) A Sambuca  may also be placed on the market as a liqueur as a Sambuca necessarily complies 
simultaneously with the requirements for categories 33 and 36 of Annex I  
3) A Gin may also be placed on the market as a juniper -flavoured s pirit drink  if it complies with 
both the requirements for categories 19 and 2 0 of Annex I  
Article 10( 5), point (a): a geographical indication  referred to in Chapter III, 
which may supplement or replace  its legal name;  
#02 - Examples  of permitted labelling : 
1) A Cognac may be placed on the market as Cognac or eau-de-vie de  Cognac   
2) A Cassis de Dijon  may be placed on the market as Cassis de Dijon  or Crème de Cassis de Dijon  
Article 10( 5), point (b): a compound term  that includes the term ‘ liqueur ’ or 
‘cream ’, which may replace  its legal name in derogation from Article 10(6) , 
point (c), according to which a compound term may only supplement a legal 
name (see § 2.1 below ), provided that it complies with the respective 
requirements laid down for category 33 of Annex I (i.e. liqueur);  
c) FORBIDDEN : 
Article 10( 7), first  subpara graph : legal names  permitted under a category  of 
spirit drinks  and geographical indications  for spirit drinks  shall not be used  
in the description, presentation or labelling of any beverage  (i.e. alcoholic or 
not alcoholic) which does not comply with the requirements  set out for that 
category or geographical indication (see also § 3.3 below ). 
This prohibition applies even in presence of terms such as ‘like, ‘type’, ‘style’, 
‘made’, ‘flavour’ , used with the purpose of indicating to the consumer that 
such beverage is not to be confused wit h the spirit drink referred to.  
The only exceptions  to this prohibition are allowed for ‘ compound terms ’, 
‘allusions ’ and ‘ ingredients lists ’ as set out in Ar ticles 11, 12 and 13(2) to (4).  
 NB: With Regulation (EU) 2019/787, Articles 9(4) and 9(7) of Regulation 
(EC) No 110/2008 were merged into the new Article 10(7)  of the SDR. 
Consequently, the provision laid down in Article 10(7) , first 
subparagraph , has become stricter with respect to Article 9(7) of 
Regulation (EC) No 110/2008, which only prohibited the use of a spirit 
drink name on alcoholic beverages  (and not ‘any beverage ’ as in the 
new SDR) not complying with all requirements laid d own for that spirit 
drink.  This change in wording was necessary to ensure consistency 
with Article 9(4) of Regulation (EC) No 110/2008, which prohibits  the 
use of sales denominations of spirit drink categories to describe or 
present in any way whatsoever any drink  other than the spirit drinks 
for which those names are listed in Annex II or registered in Annex III.  
#03 - Examples  of forbidden labelling : 
1) Whisky -type beverage   
2) Cognac -flavoured drink  
3) Zero alcohol Brandy  General Labelling Rules for Spirit Drinks  
9 4) Non-alcoholic Gin  
 NB: Regulation (EU) 2019/787 introduced a novelty with respect to the 
reference to spirit drink names in foodstuffs  other  than beverages . In 
fact, according to Article 10(7),  second subparagraph , flavourings  
that imitate a spirit drink or foodstuffs other than a beverage  having 
used such flavourings in their production, may bear in their 
presentation and labelling references to legal names permitted under 
a category of spirit drinks . The only condition is that the consumer is 
properly informed by accompanying those legal names with the term 
‘flavour’ or other similar terms. However, names of geographical 
indications may not be used  to that purpose.  
#04 - Examples  of permitted labelling  (categories) in case of use of a flavour ing imitating a spirit 
drink : 
1) Rum flavour  for bakery - Rum flavoured  cake – or - Pineapple sauce with  rum flavour  
2) Gin flavour  – Gin flavour ed ice cream - or - Yogurt with gin flavour  
3) Whisky flavour  – Whisky flavour ed chocolate - or - Candy  with whisky flavour  
#05 - Examples  of forbidden labelling  (GIs) ( allowed however  if the authentic  GI is used rather than  
a flavour ing): 
1) Cognac  food flavour                             
2) Ouzo flavoured bonbons                            
3) Cake with  Scotch Whisky flavour  
4) Ron de Guatemala  flavoured sauce  
1.4. Terms that may supplement legal names  
Article 10(6) provides an indicative list  of terms that may supplemen t legal 
names of spirit drinks.  
In this context, the verb ‘to supplement ’ should not be understood as a 
requirement for the concerned term to form in tegral part of a legal name. It 
rather indicates that it can be added to the label as an extra element to provide 
further descriptive informati on with respect to the product.  
Therefore, the ‘supplementing term ’ does not necessarily have to be displayed 
on the same line as the legal name but may appear anywhere on the label.  
Accordingly, the following may appear on the label along with the legal 
name : 
(a) ‘a name or geographical reference8 provided for in the laws, regulations 
and administrative provisions applicable in the Member State in which 
the spirit drink is placed on the market, provided that this does not 
mislead the consumer ’: this possibility is reserved to terms that are 
regulat ed at national level, where they exist. In that case those terms may 
supplement t he legal name of spirit drinks placed on the domestic market. 
Those spirit drinks may also be placed on the market of another Member 
State on condition that they are not consi dered as misleading for 
consumers of that Member State;  
#06 - Examples : 
                                                 
8  This provision does not refer to geographical indications regulated by Chapter III of the SDR.  General Labelling Rules for Spirit Drinks  
10 1) Gammel Dansk – bitter commonly known as such in Denmark  although it could be produced 
outside of Denmark  
2) Berliner Gin  or Bodensee Obstler  – terms regulated by German regulations  
3) Korenwijn – (vruchten)brandewijn – terms regulated by Dutch  law for spirit drinks placed on 
the domestic market  
(b) ‘a customary name  as defined Article 2(2) , point (o) , of Regulation (EU) 
No 1169/20119, provided that this does not mislead the consumer ’: this 
possibility is reserved to names that are traditionally used in Member 
States even if they are not formally regulated. Such names may 
supplement  the legal name of spirit drinks placed on national markets 
where they are accepted by consumers without that name needing further 
explanation ; 
#07 - Examples : 
1) Raki a: term commonly used for certain spirits in Bulgaria  
2) Schnaps - Klarer : terms commonly used for certain spirits in Germany  and Austria  
3) Brännvin  or sprit: terms commonly used for spirits in Sweden  
4) Viski : term commonly used for whisky  in Estonia  
5) Nalewka : term commonly used in Poland for spirit drinks produced by macerating plant 
materials in EAAO , distillates of agricultural origin or spirit drinks  
(c) ‘a compound term  or an allusion  (on liqueurs)  in ac cordance with 
Articles 11 and 12 ’ of the SDR  (with the exception of compound terms 
resulting from the combination of the name of a spirit drink with the term 
‘liqueur’ or ‘cream’), which may replace legal names in accordance with 
the provision of Article 1 0(5), point (b)). 
It is to be noted that, in line with Article 11(2), the terms ‘alcohol’, 
‘spirit’, ‘drink’, ‘spirit drink’ and ‘water’ may not be part of a compound 
term describing an alcoholic beverage, except if those terms are integral 
part of the leg al name of the spirit drink category that is mentioned in the 
compound term. Consequently, a compound term may in no case be 
written in such a way as being part of the generic legal name ‘spirit drink’;  
#08 - Examples  of permitted labelling : 
1) Spirit Drink  
Grain spirit and Ginger (legal name ‘Spirit Drink’ supplemented by a compound term)  
2) Chocolate Cream (L iqueur )  
with a scent of Rum  (legal name ‘Chocolate Cream’ supplemented by an allusion)  
#09 - Examples  of forbidden labelling  (terms that may not be part  of compound terms ): 
1) Ginger Whisky Spirit Drink   
2) Rum Water  
(d) ‘the term ‘blend’, ‘blending’ or ‘blended’ , provided that the spirit drink 
has undergone blending in accordance with Article 3 , point (11)’;  
 NB: this indication is compulsory in the case referred to in Article 13(3 a) 
#10 - Examples  of permitted labelling : 
1) Blended Whisky  (legal name ‘Whisky’ + supplementing term)  
2) Blend of Rums  (legal name ‘Rum’ + supplementing term)  
                                                 
9  Article 2(2), point (o), of the FIC Regulation:  ‘customary name’ means a name which is accepted 
as the name of the food by consumers in the Member State in which that food is sold, without that 
name needing further explanation . General Labelling Rules for Spirit Drinks  
11 #11 - Examples  of forbidden labelling : 
1) Blended Spirit Drink * 
2) Blend of Whisky and Vodka * 
*According to Article 3 , point (11), ‘to blend’ means to combine  two or more spirit drinks of the 
same category  that are distinguishable only by the minor differences in composition  indicated 
therein . Therefore, a g eneric ‘spirit drink’ (i.e. not belonging to a spirit drink category) or spirit 
drinks belonging to different categories may not be labelled as a blend.  
(e) ‘the term ‘mixture, ‘mixed ’ or ‘mixed spirit drink’ , provided that the 
spirit drink has undergone mixing in accordance with Article 3 ,point (9)’; 
 NB: this indication is compulsory in the case referred to in Article 13(3)  
#12 - Examples  of permitted labelling : 
1) Rum & Gin  (list of alcoholic ingredients)  
Mixed Spirit Drink  (legal name ‘Spirit Drink’ + supplementing term)  
2) Spirit Drink  (legal name)  
Mixture  of rum and gin  (list of alcoholic ingredients + supplementing term)  
#13 - Examples  of forbidden labelling : 
1) Fruit Spirit and Orange Juice  
Mixed  spirit drink*  
2) Mixture of  Aquavit and Water*  
*According to  Article 3 , point (9), ‘to mix’ means to combine  a spirit drink  (category or GI) with 
one or more of the following : other spirit drinks  that do not belong to the same category of spirit 
drinks, distillates  of agricultural origin , ethyl alcohol  of agricultural origin . Therefore, the 
combination of a spirit drink with a non -alcoholic ingredient or with water  may not be labelled 
as a mixture . 
(f) ‘the term ‘ dry’ or ‘ dry’ [i.e. in English or in any other official EU 
language ], provided that the spirit  drink has not been sweetened, not even 
for rounding off the taste ’. The following exceptions  apply in case of:  
(i) ‘spirit drinks that comply with the requirements of category 2 of 
Annex I’ (i.e. whisky or whiskey ), which may in no case be 
sweetened, not even  to round off the taste and may thus never be 
labelled as ‘dry’ or ‘ dry’10; 
(ii) spirit drinks that comply with ‘the specific requirements laid down in 
categories 20 to 22 of Annex I’ (i.e. gin, distilled  gin and London 
gin), to which specific sweetening and lab elling rules should continue 
to apply in relation to the use of the term ‘ dry’, (i.e. a content of 
added sweetening  not exceeding 0,1 grams of sweetening products 
per litre of the final product, expressed as invert sugar);  
(iii) ‘spirit drinks that comply with the requirements of category 33’ (i.e. 
liqueur ), which must be sweetened by definition. The term  ‘dry’ or 
‘dry’ may supplement the legal name of a liqueur that is  
‘characterised in particular by a tart, bitter, tangy, acerbic, sour or 
citrus taste, regardl ess of their degree of sweetening ’ (recital 17). In 
fact, the use of the term ‘dry’ in the description, presentation and 
labelling of liqueurs is not likely to mislead the consumer, as they are 
required to have a minimum sugar content to be classified as s uch. 
                                                 
10  The same exception applies by analogy  to spirit drink GIs whose technical file/ product 
specification forbids  any sweetening, even to round off the taste (e.g. Pálinka): as all spirit drinks 
belonging to the concerned GI are not sweetened at all, it would be misleading to label any of 
them as ‘dry’.  General Labelling Rules for Spirit Drinks  
12 #14 - Examples  of permitted labelling : 
1) Dry Cider Spirit  (if not sweetened, not even to round off the taste)  
2) Dry Gin  (if the added sweetening products do not exceed 0,1 grams per litre)  
3) Liqueur Triple Sec (if the liqueur is characterized e.g. by a tart  or bitter taste)  
#15 - Examples  of forbidden la belling : 
1) Dry Whisky  (never possible because all whiskies must be unsweetened)  
2) Dry Brandy  (where the brandy has been sweetened to round off the taste)  
1.5. Voluntary food information  (FIC Regulation)  
In addition to the above, in compliance with  the FIC  Regulation, voluntary 
food information11 may be provided in the description, presentation and 
labelling of a spirit drink.  
Article 36(2) of the FIC Regulation requires that ‘ food information provided 
on a voluntary b asis shall m eet the following requirements:  
(a) it shall not mislead the consumer,  as referred to in Article 7;  
(b) it shall not be ambiguous or confusing for the consumer; and  
(c) it shall, where appropriate, be based on the relevant scientific data ’. 
Voluntary information  may include terms  such as ‘fine’, ‘extra’, ‘ premium ’, 
‘deluxe’, ‘100% pure grain’ , ‘superior’, but also ‘ matured in wine cask ’, ‘old 
barrel matured’, ‘aged in Sherry cask’12, ‘Stout/Beer cask finish’,  etc. 
Terms referring to the storage  of a spirit drink for the entire maturation period 
or part of it in wooden casks having previously used to mature  another spirit 
drink  cannot be considered as mere  voluntary information within the meaning 
of Article 36 of the FIC Regulation , contrary to r eferences to e.g. wine and 
beer casks. This is  due to the prohibition laid down in Article 10(7) , first 
subparagraph,  of the SDR to use spirit drinks names in the description, 
presentation or labelling of any beverage not complying with the requirements 
laid down in the SDR or the relevant GI technical file/ product  specification. 
The only exceptions allowed to this prohibition r elate to the labelling of 
compound terms, allusions and ingredients list, as regulated by Articles 11, 12 
and 13(2) to (4) of the SDR. Therefore, the reference to a spirit drink in whose 
wooden cask another spirit drink has been  subsequently  matured is an allusion 
governed  by Article 12(3a) of the SDR13 (see § 3.2.4 .2 below).  
 NB: This section does not cover terms permitted by the technical 
file/product specification of a spirit drink GI, which may in any case 
                                                 
11  See Chapter V of the FIC Regulation.  
12  When in the descripti on, presentation or labelling of a spirit drink reference is made to a (spirit 
drink or wine) GI, the wooden cask of which has been used for the storage of that spirit drink, it 
is essential that the food business operator can prove on the basis of objecti ve elements that that 
cask has indeed been previously used for the ageing of the GI referred to.   
13  Introduced by Commission Delegated Regulation (EU) 2021/1465 of 6 July 2021  amending 
Regulation (EU) 2019/787 of the European Parliament and of the Counci l as regards the 
definition of allusions to legal names of spirit drinks or geographical indications for spirit drinks 
and their use in the description, presentation and labelling of spirit drinks other than the spirit 
drinks to which allusion is made  (OJ L 321, 13.09.2021, p. 12 ). General Labelling Rules for Spirit Drinks  
13 supplement the GI, provided that this does not mislead the consumer, 
in application of Article 10(5) , point (a). 
 NB: It is worthwhile reminding that certain spirit drink categories (in 
particular categories 1 to 14 of Annex I) may not be flavoured, 
coloured, sweetened or subject to the addition of al cohol: these 
requirement may not be circumvented by maturation in wooden casks 
which have not been fully emptied of their previous contents . 
Nevertheless, storage in empty wooden casks having previously 
contain ed another alcoholic beverage  is not regarded as flavouring 
and the reference to such practice on the label of a spirit drink should 
have the sole objective to inform the consumer of the type of 
container used for storing it and must comply with Article 7 of the 
FIC Regulation and Arti cle 21 of the SDR. Moreover, concerning 
spirit drink GIs, the labelling of such practice must be consistent with 
the requirements set out in the technical file/product specification for 
the use of such descriptors for any given GI.  
As the SDR does not regu late the use of voluntary information  in the 
presentation, description and labelling of spirit drinks, the general provisions 
of the FIC Regulation  are of application.  
According to Article 7(1) of the  FIC Regulation:  
‘Food information shall not be misleadi ng, particula rly: 
a) as to the characteristics of the food and, in particular, as to its nature, 
identity, properties, composition, quantity, durability, country of origin or 
place of provenance, metho d of manufacture or production;  
b) by attributing to the food  effects or proper ties which it does not possess;  
c) by suggesting that the food possesses special characteristics when in fact 
all similar foods possess such characteristics, in particular by specifically 
emphasising the presence or absence of certain ingred ients and/or 
nutrients;  
d) by suggesting, by means of the appearance, the description or pictorial 
representations, the presence of a particular food or an ingredient, while in 
reality a component naturally present or an ingredient normally used in 
that food has been substituted with a different component or a different 
ingredient. ’ 
The national competent authorities are responsible for the enforcement of the 
EU legislation and it is therefore up to them to assess on a case -by-case basis 
whether the use on the  label of spirit drinks of such voluntary information is 
compliant or not wi th the relevant EU legislation.  
This assessment should thus take into account, among others, that the terms  
used: 
 describe the true nature and specific characteristics of the product  (e.g. 
mentioning a specific production feature);  
 describe production features that are allowed by the requirements for the 
production of a spirit drink category or GI (laid down respectively in Annex 
I of the SDR  or in the relevant technical file/ product specification);  General Labelling Rules for Spirit Drinks  
14  describe production features that are allowed by the requirements for the 
production of the foodstuff category or GI to which reference is made (e.g. 
wine products or beer GIs);  
 are correctly referred to a GI (e.g. in the case of Sh erry casks, that they 
have been declared compliant by the relevant control and certification 
body);  
 distinguish special characteristics of the product on which they are used, 
from other (similar) products with which it might be confused ; 
 are not misleading  for the addressed consumers . 
Therefore, if  certain  terms are used  as voluntary information  with reference to 
a spirit drink , the food business operator  must be  able to demonstrate that the 
spirit drink  possesses specific characteristics in terms of qualit y, material 
value , production method  or a maturation period , which  set it apart from spirit 
drinks that comply with the minimum requirements of the same category . 
#16 - Examples  of permitted labelling  and of  relevant conditions for the use of voluntary 
information : 
1) Fine Kirsch or Edelkirsch could indicate the exclusive use of t able fruit instead of windfalls  
2) Organic Mirabelle  indicate s the exclusive use of organically grown fruit or fruit from controlled 
integrated farming  in compliance with the provisio ns of Regulation (EU) 2018/84814 and that the 
spirit drink is certified as organic  
3) Brandy  
Superior or Premium  could indicate , for instance, a particularly long maturation period  
4) Single Malt Whisky  
Matured in a Chardonnay Wine Cask  could indicate that the Whisky has spent sufficient time in a 
cask/barrel previously used to age chardonnay wine to have an effect on the organoleptic 
character of the spirit drink*  
*According to point 2(a)(iii) of Annex I (whisky or whiskey), the maturat ion of the final distillate shall 
be carried out in wooden casks not exceeding 700 litres capacity. Since the type of wooden cask is not 
specified, it is possible to reuse casks in which other alcoholic beverages were previously matured in 
order to confer particular organoleptic characteristics to the whisky/whiskey.  
#17 - Examples  of forbidden la belling  and illegitimate uses of voluntary information : 
Whisky  
Finished Sparkling Wine Cask  
is not allowed because for sparkling wines only bottle or pressurized tank fermentation transforms still 
wine to sparklin g wine by capturing the sparkle  
 NB: Reference to a protected name in the type of cask used to mature a 
spirit drink must only be for the purpose of informing the consumer of 
the type of cask used and must comply with the requirements of  
Article 21 of the SDR and Article s 7 and 36 of the FIC  Regulation . 
1.5.1.  Name of a  foodstuff  used in the production  
The name of a foodstuff  that has been used in the production  of a spirit drink 
in accordance with the requirements laid down in  Annex I for a spirit drink 
category or, in case of a GI, in its technica l file/ product specification , may also 
                                                 
14  Regulation (EU) 2018/848 of the European Parliament and of the Council of 30 May 2018 on 
organic production and labelling of organic products and repealing Council Regulation (EC) No 
834/2007 ( OJ L 150, 14.6.2018 , p. 1).  General Labelling Rules for Spirit Drinks  
15 be indicated in its presentation, description and labelling as voluntary 
information15. 
In fact, as we will see later (see § 2.1 below ), the combination of the legal name 
of a spirit drink with the name of a foodstuff provided for/allowed in its 
production does not account as a compound term  according to Article 3 , point 
(2), which defines it as the combination of the name of a spirit drink with 
(among others) ‘ the nam e of one or more foodstuffs other than foodstuffs used 
for the production of that spirit drink  in accordance with Annex I  […]’ . 
The name of a foodstuff/foodstuffs used in the production of a spirit drink may 
be indicated to inform the consumer as to the ra w material(s) conferring specific 
organoleptic characteristics to it, on condition that this indication is true, 
accurate and not misleading for the consumer.  
In that case, the legal name remains the name allowed under the spirit drink 
category or in the technical file/ product specification of a GI.  
#18 - Examples  of permitted  indication of one or more main foodstuffs  used to produce the spirit drink : 
1) Distilled Hops Gin                              -      Distilled Rhubarb and Ginger Gin *  
2) Peach Liqueur  - Coffee Liqueu r      -      Chocolate Cream (Liqueur) ** 
3) Coffee Advocaat                                -       Egg Liqueur with Speculoos***            
* According to point 2 1(a)(i) of Annex I, distilled gin can be produced by distilling EAAO in the presence 
of juniper berries  and of other natural botanicals , provided that the juniper berry taste is predominant.  
Therefore the names of such natural botanicals  may be used to supplement the legal na me ‘gin’. Other 
foodstuffs, not accounting as natural botanicals , such as ‘popcorn’ or ‘Riesling  grape ’ may not 
supplement the legal name ‘gin’ other than under the conditions laid down for ‘compound terms’.    
NB: point 20(a) of Annex I only allows the use of juniper berries as natural botanicals in the production 
of gin. Therefore, the addition of other natural botanicals to a gin would have to be labelled as a 
compound term (i.e. the appropriate legal name shall appear in the same visual field).  
** According to point 33(f) of Annex I, without prejudice to Articles 11 and 12 and Article 13(4), the 
legal name ‘liqueur’ may be supplemented by the name of a flavouring or foodstuff that confer s the 
predominant flavour of the spirit drink, provided that the flavour is conferred on the spirit drink by 
flavouring foodstuffs, flavouring preparations and natural flavouring substances, derived from the raw 
material referred to in the name of the flavouring or to the foodstuff , supplemented by flavouring 
substances only where necessary to reinforce the flavour of that raw material.  
*** According to points 39(c) and 40(c) of Annex I, Egg liqueur or Advocaat and Liqueur with egg may 
be produced by using - among others - flavourin g foodstuffs, such as coffee and speculoos  biscuits .  
1.6. Ethyl alcohol’s or distillates’ raw materials  
Article 13(1)  provides for stricter rules in respect of agricultural raw materials  
used for distillation : 
’The description, presentation or labelling of a spirit drink may refer to the raw 
materials used to produce the ethyl alcohol of agricultural origin or distillates 
of agricultural origin used in the production of that spirit drink only where that 
ethyl alcohol or those distillates have been obtained exclusively  from those raw 
materials. In such a case, each type of ethyl alcohol of agricultural origin or 
distillate of agricultural origin shall be mentioned in descending order of 
quantity by volume of pure alcohol .’ 
A spirit drink may only refer to the name s of raw material s 
                                                 
15  Not however the name of raw material(s) distilled to obtain the alcohol used in the production of 
a spirit drink, which is rather subject to the provisions of Article 13(1) (see § 1.6 below).  General Labelling Rules for Spirit Drinks  
16 distilled to obtain the alcohol used in its production on condition 
that those are  the only raw material s used  for distillation .  
All raw materials  used are to be mentioned in descending order  
in its description, presentation and lab elling . 
Provided that this condition is met, each type of ethyl alcohol or distillate (with 
the mention of the agricultural product used to produce them) shall be 
mentioned in descending order  of quantity by volume of pure alcohol present in 
the spirit dr ink. 
#19 - Examples  of permitted labelling : 
1) Spirit Drink : generic spirit drink  name referring to the name of the raw material (s) distilled to 
obtain it  – NB: only possible if  the resulting beverages complies with the definition of spirit drink 
(Article 2) but not with the requirements of  a category of spirit drinks  -: 
a) a spirit drink  obtained exclusively  by distilling cane sugar but not complying with the 
requirements of category 1 of Annex I (rum), e.g. because the spirit drink was sweetened in 
excess of the maximum threshold laid down for that spirit drink category,  may bear in its 
description, presentation and labelling the voluntary indication ‘ Cane Sugar Spirit  Drink ’ 
b) a spirit drink  obtained exclusively  by distilling agave and cane sugar and not complying with 
the requirements of any category of Annex I,  may bear in its description, presentation and 
labelling the voluntary indication ‘ Agave and Cane Sugar Spirit  Drink ’ 
2) Grain spirit (spirit drink  category 3): 
According to point 3(h) of Annex I  of the SDR, in the legal name ‘grain spirit’ or ‘grain brandy’, the 
word ‘grain’ may be replaced by the name of the cereal used exclusively  in the production of the 
spirit drink, e.g. ‘ Wheat Spirit ’ or ‘Oat Brandy ’ 
3) Wine spirit  (spirit drink  category 4): 
a) a wine spirit obtained exclusively  by distilling ‘Chardonnay wine’  produced in accordance with 
the applicable wine legislation may bear in it s description, presentation and labelling the 
voluntary indication ‘ Chardonnay Wine Spirit ’ 
b) a wine spirit obtained exclusively  by distilling ‘Chardonnay wine’ and ‘Merlot wine’  produced 
in accordance with the applicable wine legislation , may bear in its de scription, presentation 
and labelling the voluntary indication ‘ Chardonnay and Merlot Wine Spirit ’ 
4) Vodka (spirit drink  category 15): 
a) A vodka produced exclusively by using ethyl alcohol obtained from the fermentation of 
cereals  may bear in its description, presentation and labelling the voluntary indication ‘ Grain 
Vodka ’ 
b) A vodka produced exclusively by using ethyl alcohol obtained from the fermentation of 
cereals  and potatoes  may bear in its description, presentation and labelli ng the voluntary 
indication ‘ Grain and Potato Vodka ’* 
* According to point 15(f) of Annex I to the SDR, the description, presentation and labelling of 
vodka not produced exclusively from potatoes or cereals or both shall  prominently bear the 
indication ‘pr oduced from…’, supplemented by the name of the raw materials used to produce the 
ethyl alcohol of agricultural origin.  This indication shall appear in the same visual field as the legal 
name . 
5) Gin (spirit drink category 20):  
a) a Gin produced  with ethyl alcohol obtained by distilling exclusively grain  may bear in its 
description, presentation and labelling the voluntary indication ‘ with ethyl alcohol (of 
agricultural origin) made from grain ’*; 
b) a Gin produced with  ethyl alcohol obtained by distilling  exclusively wheat and barley  may 
bear in its description, presentation and labelling the voluntary indication  ‘with ethyl alcohol 
(of agricultural origin) made from barley and wheat / wheat and barley ’, depending on the 
proportion of pure alcohol represent ed by each * 
* According to point 20(a) of Annex I, gin is a juniper -flavoured spirit drink produced by flavouring 
ethyl alcohol of agricultural origin  with juniper berries. According to point 19(a) of the same 
annex, a juniper -flavoured spirit drink is a spirit drink produced by flavouring ethyl alcohol of 
agricultural origin or grain spirit or grain distillate or a combinatio n thereof with juniper berr ies. 
4)   Liqueur  (spirit drink category 33):  
a) a liqueur produced exclusively by using ethyl alcohol or a distillate made from pears  may bear General Labelling Rules for Spirit Drinks  
17 in its description, presentation and labelling the terms ‘ Liqueur produced with ethyl alcohol  
from pears ’ or ‘Liqu eur produced with pear distillate ’ respectively ; 
b) a liqueur produced by using both ethyl alcohol from pears and apricots  may be labelled as 
‘Liqueur produced on the basis of ethyl alcohol  made from pear and apricot ’ or ‘ Liqueur 
produced with ethyl alcohol  from apricot and pear ’ depending on the proportion of pure 
alcohol represented by the ethyl alcohol obtained from pears and the ethyl alcohol obtained 
from apricots . 
 NB: Reference is made here to agricultural products distilled after 
alcoholic fermentation  to produce ethyl alcohol or distillates of 
agricultural origin. Raw materials macerated in alcohol or otherwise 
added to the spirit drink according to its production requirement fall 
rather under the case of ‘foodstuff used in the production ’, which is 
dealt with in the previous § 1. 5.1, while foodstuffs that are combined 
with a spirit drink although they are not required/allowed in its 
production, are to be indicated in accordance with the rules on 
compound terms  or allusions . 
1.7. Plant raw materials used as legal names  
According to Article 13(5), ‘ the use of the names of plant  raw materials which 
are used as the legal names of certain spirit drinks shall be without prejudice to 
the use of the names of those plant raw materials in the present ation and 
labelling of other foodstuffs. The names of such raw materials may be used in 
the description, presentation or labelling of other spirit drinks, provided that 
such use does not mislead the consumer’.  
This provision was deemed necessary to allow t he use of names of fruits or 
plants that the SDR reserves as legal names for certain spirit drinks also in the 
presentation and labelling as ingredients (as fruit or plants and not as spir it 
drinks) of other foodstuffs.  
The same possibility applies to othe r spirit drinks, as long as it is made clear in 
the description, presentation and labelling that it is not the spirit drink that is 
referred to (as an ingredient) but the plant raw material itself.  
#20 - Examples : 
1) Kirsch  (legal name for fruit spirit: category 9): the German term ‘K irsch’ (cherry) may be used in:  
a) the presentation and labelling of cherry cake ( ‘Kirschkuchen’ ) even if it was the fruit that was 
used to produce the food stuff and not the spirit drink;  
b) the descr iption, presentation and labelling of a cherry liqueur  (‘Kirschlikör’ ) even if it was the 
fruit that was used to produce the liqueur and not the spirit drink, provided that there is no risk 
that the consumer is misled into thinking that the liqueur was mad e with Kirsch (spirit drink) 
and not with cherries (fruits).  
2) Anis  (legal name for the spirit drink of category 28): the French or German term ‘Anis’ (an iseed or 
anise) may be used in:  
a) the presentation and labelling of an infusion  (‘infusion à l’anis’ ) even  if it was the 
plant/botanical that was used to produce the food stuff and not the spirit drink;  
b) the description, presentation and labelling of an aniseed liqueur  (‘Liqueur d’anis ’) even if it 
was produc ed by infusing aniseed into alcohol and sugar and not by using the spirit drink, 
provided that the consumer is informed as to how the liqueur was actually manufactured.  
3) Gentian  (legal name for the spirit drink of category 18): the term ‘Gentian’ (along with its 
translations in other EU official languages) may  be used in:  
a) the presentation and labelling of an infusion  (‘Gentian tea ’) even if it was the plant/botanical 
that was used to produce the food stuff and not the spirit drink;  
b) the presentation and labelling of a food preparation such as Gentian salad . General Labelling Rules for Spirit Drinks  
18 4) Blutw urz (term used in the German liqueur GI ‘Blutwurz’): the German term ‘Blutwurz’ (i.e. root of 
the tormentil plant or Potentilla erecta (L.) Raeusch ) may be used in:  
a) the description, presentation and labelling of a nother  liqueur (Blutwurz el Likör)  as main 
flavouring used for the production of that spirit drink ; 
b) the description, presentation and labelling of another spirit drink (e.g. Blutwurz el Spiritu ose) 
produced by infusion (or maceration  and distillation) . 
  Compound terms  
19 2. COMPOUND TERMS  
Article 3 , point (2) Definition  
Article 11  Conditions for use and labelling provisions  
2.1. What is a compound term  
The use of a compound term is an option available to describe a spirit drink 
(category or GI), from which all the alcohol in the product originates, to which 
other  foodstuffs are added and  which , as a consequence, is no longer entitled to 
bear in its description, presentation or labelling the legal name of that category 
or GI. Instead, it must use the legal name ‘spirit drink’16, except when it 
complies with the requ irements permitting the use of a compound term that 
includ es the terms  ‘liqueur’ or ‘cream’17 as a legal name.  
If the resulting product does not comply with the definition of and requirements 
for a spirit drink  (e.g. because of an alcoholic strength below 1 5% vol.18), it will 
have to bear the appropriate alcoholic beverage name in accordance with Article 
17 of the FIC Regulation (NB: which is never the brand name19). 
According to Article 3 , point (2), ‘‘compound term’ means, in relation to the 
description, presentation and labelling of an alcoholic beverage, the 
combination of either a legal name provided for in the categories of spirit 
drinks set out in Annex I or the geographical indication for a spirit drink, from 
which all the alcohol of the final produc t originates, with one or more of the 
following:  
(a) the name of one or more foodstuffs other than an alcoholic beverage and 
other than foodstuffs used for the production of that spirit drink in 
accordance with Annex I, or adjectives deriving from those na mes;  
(b) the term 'liqueur' or 'cream'.’ . 
So, in either case:  
- the alcoholic ingredient is a spirit drink  category or GI  (one only) to 
which one or more foodstuffs (e.g. juices  or other non-alcoholic drink s, 
herbs, spices, sugar, dairy products) are added to confer additional specific 
organoleptic properties to the final product ; 
                                                 
16  In the case of ‘vodka’ (spirit drink category 15), when ingredi ents are added to provide to it a 
predominant flavour other than that of the raw materials used to produce it, in accordance with 
point 31(e) of Annex I of the SDR, its legal name must  be ‘flavoured vodka’ or ‘vodka’ 
supplemented by the name of any predomi nant flavour (spirit drink category 31).  
17  According to the fourth indent of point (d) of category 33. Liqueur, ‘ without prejudice to point 
(2) of Article 3, point (b) of Article 10(5) and Article 11, for liqueurs containing milk or milk 
products, the leg al name may be ‘cream’ supplemented  by the name of the raw material used 
conferring on the liqueur its predominant flavour, with or without the term ‘liqueur’’.  
18  ‘except in the case of spirit drinks that comply with the requirements of category 39 of An nex I ’ 
as provided for in Article 2, point (c), of the SDR.  
19  According to Article 17(4) of the FIC Regulation, ‘ the legal name may not be replaced by […] a 
brand name’.  Compound terms  
20 - the foodstuff/foodstuffs combined with the spirit drink are neither a 
beverage containing alcohol n or any foodstuffs  required/allowed  for its 
production  according to the relevant rules ; 
- the combination results  necessarily in an alcoholic beverage , i.e. either 
another spirit drink with the minimum required alcoholic strength of 15% 
by volume or an alcoholic beverage with less than 15% ABV;  
- all the alcohol  of the final product must originate from the spirit drink  
referred to in the compound term (i.e. the final product may not contain any 
other alcohol ic component , except for the alcohol that may be present in 
flavourings, colours or other authorised ingredi ents used for the production 
of the final alcoholic beverage – see also § 2.2 below) . 
 NB:  even the use of the terms ‘liqueur’ or ‘cream’  in a compound term 
highlight the fact that sweetening and/or milk products were added 
to a spirit drink for whose pr oduction they are not allowed or, at 
least, not in such quantity . 
Compound terms  represent an exception to the rule  forbidding the use of legal 
names for spirit drinks to describe beverages  that do not comply with all the 
requirements laid down for those spirit drinks.  
Compound terms  are used to describe  alcoholic beverages  resulting from the 
combination  of certain foodstuff (s) with a spirit drink  category or GI  which 
would thus no longer b e entitled to be labelled  as such.  
 NB:  The name of the foodstuff/foodstuffs may also be expressed by using an 
adjective referring to that/those foodstuff(s) . 
 NB:  In a compound term, the spirit drink name and the name of the 
foodstuff(s) may be combined  with or without preposition.  
#21 - Examples  of permitted  compound terms : 
1) Scotch Whisky with honey – Scotch Whisky  and Honey*  
2) Gin and tonic – Whisky & Co la – Coco Rum * 
3) Grape Marc with C innamon and Cacao * 
4) Brandy L iqueur ** 
5) Whisky Cream ** 
* In these cases the (legal) name of the final product shall be provided along with the compound term.  
** In these cases the compound term  is also the legal name . 
Article 11(2) excludes explicitly following terms from being part of a 
compound term describing an alcoholic beverage (except if any of those terms 
is part of a legal name, for instance  ‘spirit ’, e.g. in ‘wine spirit’ or ‘fruit spirit’, 
or the German term ‘Wasser ’, e.g. in Kirschwasser ): 
- alcohol  
- spirit  
- drink  
- spirit drink  
- water  
Such exclusion highlights the interdiction of the use of names relating to 
foodstuffs that are naturally part of it and aims also at preventing practices that 
are misleading for the consumer.   Compou nd terms  
21  NB:  For instance, a rum containing sweetening products in excess to the 
allowed threshold of 20 grams per litre,  which is thus no longer a rum  
but must bear the legal name ‘spirit drink’ , may not display the 
compound term ‘sugar rum’ or ‘ cane  sugar rum’. If other foodstuffs not 
allowed under category  1 of Annex I are added, the term rum may 
appear in a compound term such as  ‘rum & spices’ . If not , the resulting 
product  will have to be labelled as e.g. ‘spirit drink  with cane sugar ’ (to 
indicate that sugar was added to it) or ‘cane sugar  spirit drink ’ (to 
indicate that sugar was distilled to produce the spirit drink that, 
however, does not comply with other production requirements for rum) . 
#22 – Examples  of forbidden  compound terms : 
1) Brandy & alcohol            or        Cognac and Alcohol  
2) Whisky based spirit         or         Scotch Whisky Spirit  
3) Drink based on Rum       or         Ron de Guatemala Drink  
4) Cane s ugar Rum            or          Cuba rum and sugar  
5) Liqueur spirit drink       or          Irish Cream Spirit Drink  
6) Gin water                      or          Genever Water  
According to Article 10 (6), point (c), a compound term may only supplement 
the legal name of a spirit drink. Therefore, a compound term cannot be used 
as a legal name  for a spirit drink . 
The only exception  to this rule is represented by compound terms that include 
the term ‘ liqueur ’ or ‘ cream ’, which, according to Article 10(5), point (b), may 
replace the legal name  provided that the resulting beverage complies with the 
relevant requirements laid down in the spirit drink category 33 ‘liqueur’ of 
Annex I . 
#23 - Examples  of permitted compound terms  that include the term ‘liqueur’  or ‘cream’  : 
1) Vodka liqueur (EN)                                         -      Irish Whiskey Cream (EN)  
2) Wodkalikör – Likör aus /mit Wodka (DE)        -      Berliner Kümmelcre am (DE)  
3) Liqueur à la vodka (FR)                                 -     Crème de Cognac (FR)  
4) Liquore alla vodka (IT)                                  -     Crema di Grappa (IT)  
5) Licor de vodka (ES)                                       -     Crema de Orujo de Galicia (ES)  
6) Likier na bazie wódki (PL)                            -     Krem na bazie Polskiej Wódki (PL)  
In all the cases listed above, the following must be  complied with : 
a) the spirit drink referred to must be authentic , e.g. it must comply with the requirements laid down by 
the respective spirit drink category or GI, including its minimum alcoholic strength -> i.e. no 
dilution with water reducing it below the minimum provided; and 
b) the alcohol used in its production originates exclusively from the spirit drink referred to in the 
compound term (except for the alcohol that may be present in flavourings, colours or other 
authorised ingredients used for the production of that beverage) -> i.e. no addition of other spirit 
drinks or ethyl alcohol of agricultural origin or distillates of agricultural origin of any sort; and 
c) the requirements laid down in category  33 of Annex I for the use of the legal name ‘ liqueur ’ (i.e. a 
minimum alcoholic strength of 15% by volume and a minimum content of sweetening product of 100 
grams per litre) or ‘ cream ’ (i.e. all of the above + use of mi lk or milk products) . 
2.2. Conditions of use  
Article 11(1) provides for the following conditions of use of a spirit drink  name 
(category or GI) in a compound term:  
‘(a) the alcohol  used in the production of the alcoholic beverage originates 
exclusively  from the spirit drink  referred to in the compound term, except Compound terms  
22 for the alcohol that may be present in flavourings, colours or other 
authorised ingredients used for the production of that alcoholic beverage; 
and 
(b)  the spirit drink has not been diluted  by addition of water  only, so that its 
alcoholic strength is below the minimum strength  provided for under the 
relevant categ ory of spirit drinks set out in Annex I20.’ 
Therefore, the use of a spirit drink name in a compound term is only allowed 
under the condition that:  
a) only the authentic  spirit drink has been used, as the name of a spirit drink 
(category or GI) may not be displayed if the product it refers to does not 
comply with all requirement s laid down for its production;  
 NB:  in other words, it must comply with all requirements lai d down in 
the relevant spirit drink category or GI technical file/product 
specification.  
b) no alcohol other than the alcohol originating from the spirit drink referred 
to may be added to the final product, with the exception of the alcohol that 
may be presen t in flavourings, colours or other authorised ingredients used 
in its production;  
 NB: in other words:  
 the spirit drink referred to may not be deprived of its alcohol (i.e. 
no flavouring compounds extracted from the spirit drink are 
allowed) and,  
 no addit ional ethyl alcohol/distillates/other spirit drinks may be 
added.  
c) the addition of water is only allowed to the extent that the spirit drink still 
maintains the prescri bed minimum alcoholic strength.  
 NB: this prohibition only applies to water as the spiri t drink may be 
combined with other non -alcoholic liquid foodstuffs (e.g. fruit 
juices, dairy products) which will obviously also have the effect to 
proportionally reduce the overall alcoholic strength of the final 
product.  
                                                 
20  In case C -136/96 , related  to the sale of an under strength whisky (i.e. a whis ky diluted with water 
below 40%),  the CJEU rejected an argument by the defendant that he was entitled to benefit from 
the compound term provisions to allow him to describe his under strength whisky as ‘Blended 
Whisky Spirit ’ or ‘Spiritueux au Whisky’ . One of the reasons given for rejecting that argument 
was that the compound term provisions related only to liqueurs at that time. As it was intended in 
Article 10(1) of Regulation (EC) No 110/2008 to extend the compound term provisions to all 
spirit drinks (i.e. not just liqueurs), and to GIs, there was therefore a danger that it would be 
argued that descriptions such as ‘Scotch Whisky and spring water ’ could be used as a compound 
term on under strength ‘Scotch Whiskies ’ because all the alcohol in the product was Scotch 
Whisky. That would have defeated the whole purpose of setting a minimum strength for Scotch 
Whisky/whisky (and other defined spirits). It was for that reason that Article 10(2) was 
introduced in Regulation (EC) No 110/2008 (and confirmed in Article 11(1), point (b), of the 
new SDR) to ensure that compound terms could not be used where defined spirit drinks were 
simply diluted below their minimum strength ; Judgment of 16 Jul 1998, C -136/96, The Scotch 
Whisky Association , ECLI:  EU:C:1998:366 . Compound terms  
23 2.3. Labelling provisions  
Wher e a food  business operator decides to use a  compound term, it is not only 
necessary to establish that the resulting alcoholic beverage complies with the 
conditions for using it (see § 2.1 and 2.2 above ), but the product  is to be labelled 
accordingly.  
Article 11(3)  lays down the following labelling provisions for a compound term 
describing an alcoholic beverage, which shall:  
‘ (a)  appear in uniform characters of the same font, size and colour ; 
(b) not be interrupted by any textual or pictorial element which does no t form 
part of them;  
(c) not appear in a font size which is larger than the font size used for the name 
of the alcoholic beverage ; and  
(d) in cases where the alcoholic beverage is a spirit drink, always be 
accompanied by the legal name of the spirit drink , which  shall appear in 
the same visual field as the compound term , unless the legal name is 
replaced by a compound term in accordance with Article 10(5), point (b) .’21 
Those labelling provisions aim at ensuring that:  
(a) and (b) : the name of the spirit drink u sed in the compound term does not 
appear in a more prominent way than the name of the foodstuf f that is 
combined with it,  
(c) : the (legal) name of the alcoholic beverage does not appear in a font size 
that is smaller than the font size used for the compound t erm in order to 
avoid misleading the consumer as to the actual nature of the product;  and 
(d) when the final product is a spirit drink, its  legal name always appears in the 
same visual field as  the compound term – unless the compound term 
legitimately replaces the legal name – to avoid misleading the consumer as 
to the actual nature of the product . 
 NB:Article 11(3)  does not require that the compound term is displayed in the 
same visual field as the name of alcoholic beverages other than spirit 
drinks,  but the requirements of the FIC Regulation that food information 
shall not be misleading, particularly as to the nature and identity of the 
food (Article 7(1) , point (a), of the FIC) and that the name of the food 
shall be marked in a conspicuous place in such a way to be easily 
visible, etc. (Article 13(1) , of the  FIC) are nonetheless of application.  
 NB: Article 11(3) does not require that the legal name of the alcoholic 
beverage and the compound term are displayed on separate lines, but 
the provision la id down in Article 11(2) prohibits that terms such as 
‘drink’ and ‘spirit drink’ be part of the compound term. Therefore, 
displaying the legal name ‘spirit drink’ or the name ‘drink’ – e.g. ‘Gin 
                                                 
21 Introdu ced by Commission Delegated Regulation (EU) 2021/1335 of 27 May 2021 amending 
Regulation (EU) 2019/787 of the European Parliament and of the Council as regards the 
labelling of spirit drinks resulting from the combination of a spirit drink with one or more  
foodstuffs  (OJ L 289, 12.8.2021, p. 4) . Compound terms  
24 & Tonic (spirit) drink’ – on the same line as the compound te rm would 
not be acceptable.  
#24 - Examples  of labelling  of an alcoholic beverage with a compound term  (the particulars  indicated  in 
brackets  are not mandatory ): 
Scotch Whisky  & Honey   
Spirit drink  
Spirit drink  
Gin & Tonic    
Alc.15% Vol. 
 
   
 
Grape Marc Spirit  
with cinnamon and cacao  
SPIRIT DRINK  
         (Liqueur )                                                                               
Brandy Liqueur  
              
 
*A spirit drink produced by adding e.g. sugar and dairy products to a whisky, will only be allowed to 
bear the legal name ‘Whisky Cream’ if all the alcohol originates from authentic  whisky and the final 
product complies with the relevant requirements laid down in category 33 (i.e. liqueur), e.g. that it has a 
minimum alcoholic strength of 15% by volume and contains at least 100 grams of sweetening products 
per litre as well as milk o r milk products. Should these requirements not be complied with, the legal name 
will have to be ‘spirit drink’ if it complies with the definition and requirements for spirit drinks laid down 
in Article 2 or the appropriate name for an alcoholic beverage if  it does not.  (Alcoholic beverage ) 
Gin & Tonic  
Alc.8% Vol.  Spirit drink  
Coco  Rum  
Whisky Cream (Liqueur )* 
2.4. Checks  
Checks on the (description), presentation and labelling of a product containing a 
compound term referring to the name of a spirit drink (category or GI) address 
the compliance with following conditions:  
Production:  
1) the alcoholic ingre dient is a spirit drink category or GI (no more than one 
spirit drink) to which one or more foodstuffs that are not allowed in its 
production and that are not alcoholic beverages are added to confer 
additional specific organoleptic pr operties to the final product;  
2) the final product is an alcoholic beverage;  
3) the authentic  spirit drink has been used, i.e. it complies with all production 
requirements laid down in the relevant spirit drink category of Annex I or 
GI technical file/ product  specification, including its minimum alcoholic 
strength;  Compound terms  
25 4) all the alcohol originates from the spirit drink referred to, except  for the 
alcohol that may be present in flavourings, colours or other authorised 
ingredients;  
Labelling:  
5) the (legal) name is:  
a. ‘spirit drink’ for spirit drinks not complying with the requirements of 
any category,  
b. a compound term combining the name of the spirit drink with the term 
‘liqueur’ or ‘cream’ for a resulting spirit drink complying with the 
relevant requirements of categor y 33 of Annex I, or  
c. the name of the alcoholic beverage, if it is not a spirit drink (e.g. with 
less than 15% ABV)  in accordance with the FIC rules22; 
6) in the compound term, the name of the spirit drink is combined either with 
the term ‘liqueur’ or ‘cream’ (i f complying with the relevant requirements 
as indicated under point 5.b. above) or with the name of/adjective for 
foodstuffs that are not allowed in its production;  
7) the (legal) name of the alcoholic beverage must be displayed in a 
conspicuous way so as to be easily visible, clearly legible and, where 
appropriate, indelible. It shall not in any way be hidden, obscured, detracted 
from or interrupted by any other written or pictorial matter or any other 
intervening material;  
8) the legal name of the spirit drink resulting from the combination of a spirit 
drink with one or more foodstuffs always appears in the same visual field as 
the compound term  (unless the compound term is also the legal name of the 
spirit drink in application of Article 10(5), point (b), of the SDR)23; 
9) without prejudice to the legal names provided for in Article 10, the terms 
‘alcohol’, ‘spirit’, ‘drink’, ‘spirit drink’ and ‘water’ shall no t be part of the 
compound term;  
10) the compound term is written in uniform characters of the same font, size 
and colours;  
11) the words composing the compound term are not interrupted by any textual 
or pictorial element wh ich does not form part of them;  
12) the compound term appears in the same font size used for the (legal) name 
of the alcoholic beverage or smaller .  
                                                 
22  Concerning the name of alcoholic beverages other than spirit drinks, Article 17 of the FIC 
Regulation is of application ‘ The name of the food shall be its legal name. In the absence of such 
a name, the name of the food shall be its customary name, or, if there is no customary name or 
the customary name is not used, a descriptive name of the food shall be provided .’ See respective 
definitions under Article 2(2), points (n), (o) and (p), of the FIC Regulation.  
23  Spirit drinks which do not meet this requirement but which meet the requirements of Regulation 
(EC) No 110/2008 and were produced and labelled before 31 December 2022 may continue to be 
placed on the market until stocks are exhausted.  Allusions  
26 3. ALLUSIONS  
Article 3 , point (3) Definition  
Article 12  Conditions for use and labelling provisions  
3.1. What is an allusion  
The use of an allusion is an option available under certain conditions to refer 
to the name of a spirit drink (category or GI) in the (description,) presentation 
or labelling of  another foodstuff.  
According to Article 3 , point (3), ‘'allusion' means the direct or indirect 
reference to one or more legal names provided for in the categories of spirit 
drinks set out in Annex I or to one or more geographical indications for spirit 
drinks, other than a reference in a compound term or in a list of ingredients as 
referred to in Article 13(2)  to (4) in the description, presentation and labelling 
of: 
(a) a foods tuff other than a spirit drink,  
(b) a spirit drink that complies with the requirements of categories 33 to 40 of 
Annex I, or 
(c)  a spi rit drink that complies with the conditions laid down in Article 
12(3a) .’ 
In other words,  an allusion to spirit drinks names may be made in:  
- the presentation and labelling of foodstuffs  other than alcoholic beverages ; 
- the presentation and labelling of  alcoholic beverages  other  than spirit drinks ; 
- the description, presentation and labelling of liqueurs ; 
- the description, presentation and labelling of spirit drinks other than liqueurs 
[only admitted in specific cases that could not be qualified as com pound terms 
or mixtures, for which specific labelling provisions are of application (see 
Chapters 2 above and 4 below)].  
According to Article 10(6) , point (c), an allusion may only supplement the 
legal name  of a spirit drink. Consequently, an allusion  on a spirit drink  may 
never replace its legal name  but should be added to it in accordance with the 
labelling rules provided for in Article 12(4) (see § 3.2.3 and 3.2.4  below).  
An allusion  is the reference to one or more names of  spirit drink s 
(categor ies or GIs) in the presentation and labelling  of another 
foodstuff . Where the allusion is made on a spirit drink , it may  
never be used as its legal name . 
 NB: The question was raised as to how the pro vision of Article 10(7), first 
paragraph, of the SDR – prohibiting the use of a spirit drink name 
(category or GI) in the description, presentation and labelling of any 
beverage not complying with the requirements laid down for that 
spirit drink category or G I except in case of allusions, compound 
terms and in gredients lists  – is to be understood in relation to the 
horizontal obligation to indicate details on the food business Allusions  
27 operator  in line with Articles 8(1) and 9(1)(h) of the FIC Regulation. 
In fact, it may happen that the name or the address of a food business 
operator (but also logos or registered brand names) include the name 
of a spirit drink category (e.g. ‘Guadeloupe Rum  Distilleries’ or 
‘Vodka  Brand X Company’) or GI (e.g. Bassano del Grappa ). This 
question is even more relev ant if the spirit drink upon which such 
food business operator name or address is displayed does not belong 
to the same spirit drink category (e.g. if the ‘ Vodka  Brand X 
Company’ produces gin). The reply is that the two legal obligations 
(one under SDR and  the other under FIC rules) are not necessarily 
incompatible: if the name or address of a company (lawfully) include 
the name of a spirit drink category or GI  but such name is not being 
used as the legal name of the spirit drink , that name or address 
shoul d be indicated as both provisions are applicable in parallel and 
the provision of the SDR does not prevent the indication of the 
business name  in application of the FIC . The same applies to 
descriptive name s (in the sense of Article 2(2), point (p), of the  FIC 
Regulation)  for alcoholic beverages other than spirit drinks , which 
should not be incompatible with  the prohibition to mention the name 
of a spirit drink in application of Article 10(7), first paragraph, of the 
SDR. 
3.2. Conditions of use and labelling provisions  
According to Article 12, different rules apply in case the allusion to the name 
of a spirit drink is made on:  
a) a foodstuff other than an alcoholic beverage;  
b) an alcoholic beverage other than a spirit drink;  
c) a spirit drink falling under any of cate gories 33 -40 of Annex I (liqueurs) ; or 
d) a spirit drink other than a liqueur (in specific, limited cases).  
Allusions  to spirit drinks names  may be placed on the 
(description) presentation and labelling of any type of foodstuff . 
However, allusions on spirit drinks other than liqueurs  are only 
admitted in specific, limited cases.  
 NB: In order to take into account the specific nature of the geographical 
indications  and the enhanced protection established to prevent any 
misappropriation of their reputation, i n case of allusion to a spirit drink GI  
used as an ingredient in other foodstuffs , it is recommended  that: 
1) the spirit drink  covered by the GI name should be used in sufficient 
quantity to confer an essential characteristic on the foodstuff 
concerned ; 
2) the foodstuff making allusion to one or more spirit drink GI s should 
not contain any other ‘comparable ingredient’ , i.e. any other 
ingredient which may partially or totally replace the ingredient (s) 
benefiting from a GI. I f that is the case, the GI name sh ould only 
appear in the list of ingredients, in accordance with Articles 18 to 22 of 
the FIC Regulation . Obviously, this recommendation only  applies to 
spirit drinks  belonging to the same category as the GI /GIs referred to  Allusions  
28 or to flavourings ‘imitating’ spi rit drinks , while other spirit drink 
categories can be added and labelled in application of the provisions 
on allusions ; and  
3) the percentage of incorporation  of the product covered by the GI 
name (s) is to be indicated  in or in close proximity to the allusio n to the 
spirit drink GI or, where provided, in the list of ingredients, in direct 
relation to the ingredient in question , as provided under QUID rules24. 
In case of allusions to GI names it is recommended  that: 
1)  the foodstuff should have, as one of its essential 
characteristics, a taste attributable primarily to the presence 
of th e spirit drink GI that has been used as an ingredient;  
2) no other ‘comparable’ ingredient  (except for spirit drinks  of 
other categories ) should be used; and  
3) the quantity used  should be clearly stated . 
 
#25 – Example s: 
Chocolate pralines filled with Ouzo (5%) 
would only be admissible if a sufficient quantity of authentic  Ouzo had been used to confer to the 
chocolate pralines a tast e attributable primarily to it.  
Beer  
with Rum da Madeira  (7%) 
would only be admissible if no ‘comparable’ ingredient ( e.g. another rum (with or without GI ), a 
compound aroma extracted from rum  (da Madeira)  or an ‘imitation’ rum flavour) was added to the bee r 
along with Rum da Madeira GI.  
 NB: In case not only Rum da Madeira was added to the beer but also (an)other ‘comparable’ 
ingredient (s), the GI name may not be used as an allusion but may only appear in the list of 
ingredients, along with the ‘comparable’  ingredient(s) and the ingredients used to produce the 
beer itself.  
 NB: In case not only Rum da Madeira was added to the beer  but also (an)other spirit drink (s) not 
belonging to category 1 of Annex I  (rum) , all the names  of spirit drinks are to be mentioned in 
the allusion (or in the list of ingredients ). 
 NB:  It is reminded that, according to Art icle 10(7) , second paragraph , of 
the SDR, the names of spirit drink GIs may not be used to describe 
flavourings imitating  those GIs or their use  in any foodstuff.  
3.2.1.  Allusions on foodstuffs other than alcoholic beverages  
Article 12(1) allows the allusion to the name of one or more spirit drinks 
(categories or GIs) in the presentation and labelling of a foodstuff other than 
an alco holic beverage, on condition that the ‘alcohol used in the production of 
the foodstuff originates exclusively from the spirit drink or the spirit drinks 
referred to in the allusion .’ 
The only exception allowed to th at condition is  ‘the alcohol that may be 
present in flavourings, colours or other authorised ingredients used for the 
                                                 
24  These recommendat ions mirror those included in the document ‘Commission Communication — 
Guidelines on the labelling of foodstuffs using protected designations of origin (PDOs) or 
protected geographical indications (PGIs) as ingredients (2010/C 341/03)’.  Allusions  
29 production of that foodstuff ’, i.e. the alcohol that has been used to prepare 
those ingredients.  
Except for that, all the alcohol present in the final product must thus originate 
from the authentic  spirit drink (i.e. that complies with all requirements laid 
down for the respective category or GI – including the minimum alcoholic 
strength at the time w hen it is used), without any addition of ethyl alcohol or 
distillates or other spirit drinks.  
In particular, there are two possible cases:  
a) a liquid foodstuff  other than an alcoholic beverage and other than water , to 
which more than one spirit drink25 have b een added , that will result in a n 
alcoholic beverage (i.e. a  drink  with a certain alcoholic strength, depending 
on the quantity of alcohol that is necessarily added through th ose spirit 
drink s); 
 NB:  In no case is it possible that the beverage resulting from the 
combination of a non -alcoholic liquid foodstuff  with spirit drinks 
does not contain any alcohol at all . 
b) a non-liquid foodstuff  to which one or more spirit drinks  have been added 
during its preparation , that  will necessarily result in a foodstuff w ith a 
certain residual content of alcohol, depending on the quantity of spirit 
drink(s) used. However, some of that alcohol may evaporate in prepar ation 
processes such as baking.  
The labelling of such foodstuff is not regulated by the SDR, therefore the FI C 
Regulation applies, in particular Article 36 on voluntary information and 
Article 7 on fair information practices . 
#26 - Examples  of permitted allusions  on foodstuffs other than alcoholic beverages:  
- Kirsch chocolate *                                            or       -  Cognac pralines *                           
- Egg liqueur cake *                                           or       -  Mirto di Sardegna cookies * 
- Rum & raisins ice cream *                              or       -  Génépi des Alpes ice cream *  
- Fruit nectar  refined with Rum  & Brandy ** or       -  Mixed  fruit juices  with Rum and Whisky ** 
* These are not compound terms because the resulting product is not an a lcoholic beverage.  
**In case of allusions to more than one spirit drink on non-alcoholic beverages, all the alcohol in the 
final product must originate exclusively from the spirit drinks to which allusion is made.  
3.2.2.  Allusions on alcoholic beverages other than spirit drinks  
Article 12(2) allows the allusion to the name of one or more spirit drin ks 
(categories or GIs) in the presentation and labelling of an alcoholic beverage 
other than a spirit drink, on condition that:  
‘(a) the added alcohol originates exclusively from the spirit drink  or spirit 
drinks referred to in the allusion; and  
                                                 
25  According to the  definition provided by Article 3, point (2), of the SDR, the combination of one 
spirit drink with one or more foodstuffs  resulting in an alcoholic beverage  is a compound 
term  and is subject to the specific provisions laid down in Article 11. Nonetheless, the addition 
of more than one spirit drink  to a non -alcoholic beverage is to be treated as an allusion  and is 
subject to the provisions of Article 12(1).  Allusions  
30 (b) the proportion of each alcoholic ingredient  is indicated at least once in 
the same visual field  as the allusion, in descending order of quantities 
used. That proportion shall be equal to the percentage by volume of pure 
alcohol it represents in the total pure alcohol content by volume of the 
final product. ’ 
This provision addresses all beverages containing alcohol that are not spirit 
drinks, including among others:  
1) Wine  (without prejudice to the provisions of Regulation (EU) No 
1308/201326); 
2) Aromatised wine prod ucts (without prejudice to the provisions of 
Regulation (EU) No 251/201427); 
3) Beer ; 
4) Cider, perry and other fermented beverages . 
The legislator introduced this new provision, not present in Regulation (EC) 
No 110/2008, in order to clarify the conditions applicable to the allusions to 
spirit drinks in the presentation and labellin g of other alcoholic beverages.  
In fact, this implies the addition of alcohol to the alcohol naturally present  in 
the alcoholic beverage , contradicting thus apparently the princip le that the 
alcohol must originate exclusively from the spirit drink(s) referred to.  
#27 - Examples  of permitted  allusions  on alcoholic beverages other than spirit drinks:  
1) Beer with Genever – or – Beer with a hint of Genever – or – Beer refined with Genever : all the 
alcohol added to the beer must originate from authentic  Genever (i.e. complying with all 
requirements laid down for this GI, including its minimum alcoholic strength) without addition of  
any ‘comparable’ ingredients, ethyl a lcohol, distill ates or other spirits;  
2) Hot Apple Cider with Punch au Rhum: all the alcohol added to the apple cider must originate 
from punch au rhum (i.e. complying with the requirements laid down for category 33 of Annex I 
and, in particular, the third indent of its point (d)).  
3) Alcoholic beverage  
The Diplomat * refined  with Maraschino Liqueur and Cognac : all the alcohol added to the 
alcoholic beverage  (vermouth)  must originate from authentic  Maraschino liqueur  (i.e. complying 
with all requirements laid down for categor y 37 of Annex I) and Cognac  (i.e. complying with all 
requirements laid down in its technical file/ product specification).  
*’The Diplomat’ is a cocktail containing vermouth and liqueur. Reference to it  is made here solely for the purpose 
of illustrating the possibility to make allusions on aromatised wine products. Due to the absence of provisions on 
compound terms and allusions in Regulation (EU) No 251/2014 and to the prohibition laid down therein to use 
any sales denominations reserved for aromatised wine products for alcoholic beverages not fulfilling the 
requirements laid down for their production, alternative names are to be used to describe such alcoholic 
beverages.  
 NB: The  above  examples  are descriptive  and do not apply the labelling provisions requiring that the allusion 
shall appear on a separate line as the legal name of the liqueur and in a font size which is no larger than half the 
font size used for the latter.  
                                                 
26  Regulation (EU ) No 1308/2013 of the European Parliament and of the Council of 17  December 
2013 esta blishing a common organisation of the markets in agricultural products and repealing 
Council Regulations (EEC ) No 922/72, (EEC ) No 234/79, (EC ) No 1037/2001 and 
(EC) No 1234/2007 ( OJ L 347, 20.12.2013, p. 671).  
27  Regulation (EU ) No 251/2014 of the Europea n Parliament and of the Council of 26  February 
2014 on the definition, description, presentation, labelling and the protection of geographical 
indications of aromatised wine products and repealing Council Regulation (EEC ) No 1601/91 
(OJ L 84, 20.3.2014, p.  14). Allusions  
31 #28 - Examples  of forbidd en allusions  on alcoholic beverages other than spirit drinks : 
1) Beer refined with Rum -flavour *       or        Beer flavoured with Genever compound aromas * 
2) Vermouth with  Sambuca **              or        Sangria  refined with Madeira Rum ** 
* Allusions on beverages (in this case beer) are forbidden if they refer to flavourings and not to the authentic  spirit 
drink category (rum) or GI (Genever).  
** Regulation (EU) No 251/2014 does not allow the use  of compound terms or allusions on aromatised w ine 
products and  prohibit s the  use of sales denominations reserved for aromatised wine products for alcoholic 
beverages not fulfilling the requirements laid down for their production . 
The clarification on the fact that, in case of allusions on alcoholic beverages 
the added alcohol  must originate from the spirit drink(s) referred to, allowed  
the legislator to provide that the same labelling rule previously provided by 
Article 11(5) of Re gulation (EC) No 110/2008 for mixtures only, shall now 
apply also to alcoholic beverages making allusion to one or more spirit drinks. 
This aims at informing the consumer about the proportion in the final product 
of the alcohol  deriving respectively from t he initial alcoholic beverage and the 
spirit drink(s) referred to in the allusion.  
Accordingly, in case of allusion to one or more spirit drinks, a list of alcoholic 
ingredients is to be displayed at least once in the same visual field as the 
allusion and indicating in descending order the proportion (in percentage) of 
the pure alcohol represented by each alcoholic ingredient  in the final product 
(Article 12(2) , point (b)). 
#29 - Examples  of labelling of proportion of alcohol  from each alcoholic ingredient:  
1) Beer  with Genever  (Alcohol 6% vol.: Beer 9 0% - Genever 10 %) 
2) Hot Apple Cider with Punch au Rhum (8% vol: Apple Cider 95% - Rum 5%)  
3) The Diplomat * refined  with Cognac and Maraschino  (Alc. 15% vol.: Wine 75% - Cognac 10% - 
Maraschino  8% - Ethyl alcohol of agr icultural origin 7%) 
* Regulation (EU) No 251/2014 does not allow the use  of compound terms or allusions on aromatised wine 
products and  prohibit s the  use of sales denominations reserved for aromatised wine products for alcoholic 
beverages not fulfilling the requirements laid down for their production . However, the name of a cocktail such 
as ‘Diplomat’  – which contains  Vermouth – can be used in this context. As Vermouth is an aromatised wine 
which foresees the addition of alcohol, where ethyl alcohol of ag ricultural origin is used in its production , the 
list of alcoholic ingredients should specify this in order to distinguish such alcohol from the alcohol originating 
from the wine  and from spirit drinks to which allusion is made . 
 NB: The  above  examples  are descriptive  and do not apply the labelling provisions requiring that the allusion 
shall appear on a separate line as the legal name of the liqueur and in a font size which is no larger than half 
the font size used for the latter.  
3.2.3.  Allusions on liqueurs  
Article 12(3) allows the allusion to the name of one or more spirit drinks 
(categories or GIs) in the description, presentation and labelling of a spirit 
drink that complies with the requirements of any of categories 33 to 40 of 
Annex I  (i.e. liqueurs), on  condition that:  
‘(a) the added alcohol originates exclusively from the spirit drink or spirit 
drinks referred to in the allusion;  
(b) the proportion of each alcoholic ingredient is indicated at least once in 
the same visual field as the allusion, in desce nding order of quantities 
used. That proportion shall be equal to the percentage by volume of pure 
alcohol it represents in the total pure alcohol content by volume of the 
final product; and  Allusions  
32 (c) the term ' cream ' [NB: only the English term ‘ cream ’] does not  appear in 
the legal name of a spirit drink that complies with the requirements of 
categories 33 to 40 of Annex I or in the legal name of the spirit drink or 
spirit drinks referred to in the allusion. ’ 
This provision addresses any of the categories 33 -40 (liqueurs) in derogation 
from the provisions on mixtu res laid down in Article 13(4).  
In fact, the addition of one or more spirit drinks to a liqueur would account as  
a mixture according to the definition provided for in Articles 3(9) and (10) and 
would h ave to be labelled accordingly.  
Nonetheless, the legislator introduced an exception to the scope of 
applicability of the rules on allusion, initially intended to be limited to 
foodstuffs other than spirit drinks. This was done to ensure that the consumer 
is properly informed about the content of a liqueur to which a different spirit 
drink is added to confer to it a particular organoleptic character istic. This is 
common practice, given that – among others – liqueurs may be produced by 
combining one or more spirit drinks (s ee point 33(a)(ii) of Annex I).  
In fact, the provisions on mixtures laid down in Articles 13(3) and (4) require 
that the name of spirit drinks (and other alcoholic components of the mixture) 
are to be indicated exclusively in a list of the alcoholic ingredients . Instead, 
under the provisions governing  allusions on liqueurs , the name of the added 
spirit drink(s) may appear anywhere, as long as it is in the same visual field as  
the legal name ( as required by Article 12(4), point (c), see § 3.2 .5 below).  In 
order to mitigate the risk of misuse and misleading practices, the legislator 
introduced also in case of allusions on liqueurs (as for mixtures) the 
requirement to display a list of alcoholic ingredients at least once in the same 
visual field  as the allusion and indicating in descending order the proportion 
(in percentage) of the alcohol represented by each alcoholic ingredient  in the 
final product (Article 12(3) , point (b)). 
Moreover, the labelling provisions laid down in Article 12(4) , point  (a) and 
(b), require that the allusion shall not be on the same line as the legal name of 
the liqueur and shall appear in a font size which is half (or less) the font size 
used for the legal name or possible compound term s. 
However, contrary to the list o f alcoholic ingredients for mixtures (which shall 
also be written in a font size that is no larger than half the font size used for the 
legal name: see Article 13(3),  second subparagraph and  Article 13(4) , second 
subparagraph, point (a ), as well as § 4.2.1 and 4.2.2 below) , allusion s on 
liqueurs may appear in characters that are not of the same font and colour as 
those used for the legal name.  
Finally, Article 12(4) , point (c), provides that allusion s on liqueurs  shall 
‘always be accompanied by the legal name of the spirit drink , which shall 
appear in the same visual field as the allusion. ’ (see § 3.2.5 below).  
 NB: The legislator introduced a limitation to the above p rovision , i.e. legal 
names including the term ‘ cream ’ are not permitted  when liqueurs 
make allusion to spirit drinks. This exception only applies to the term 
in English  (and not in other languages) and aims at safeguarding the 
reputation of the Irish Cream GI .     
                                                                                                                                            Allusions  
33 #30 - Examples  of permitted and forbidden  allusions on liqueurs : 
1) Egg Liqueur refined  with Brandy           or       -   Blutwurz Liqueur with Cognac  
2) Chocolate Liqueur with a shot of Gin    or       -   Licor de café de Galicia with Rum  
3) Egg Liqueur produced with Cherry Spirit (even if all the alcohol –i.e. 100% - originates from the 
Cherry Spirit, this can be referred to as an allusion)  
4) Crème  de Brandy avec Rhum           BUT NOT : Brandy Cream  avec/with Rhum  
5) Crema  de Orujo con Whisky             BUT NOT : Orujo Cream  con/with Whisky  
 NB: Egg Liqueur with a hint of vodka may be used as an allusion . Contrary to Vodka Liqueur  
which is a compound term  and, as such, does not consent the addition of alcohol other than 
that originating from vodka, in the allusion on liqueurs , the addition of alcohol is allowed  
through the recipe for the production of the liqueur. Therefore , in order to avoid misleading th e 
consumer, the indication of the proportion of alcohol from all alcoholic ingredients is 
mandatory  for allusions on liqueurs . 
 NB: Whisky cream  (in English) can only be a compound term  and, as such, requires that all the 
alcohol originates exclusively fr om whisky.  
 NB: The  above  examples  are descriptive  and do not apply the labelling provisions requiring that the allusion 
shall appear on a separate line as the legal name of the liqueur and in a font size which is no larger than 
half the font size used fo r the latter.  
 NB: Some argue that the possibility to make allusion to spirit drinks on a 
liqueur weakens the requirement that, in compound terms, all the 
alcohol must originate from the spirit drink referred to. In fact, 
whereas in a ‘Whisky Liqueur’ all the alcohol must stem from whisky, a 
‘Liqueur with (a dram of ) Whis ky’ may be produced by usi ng also 
other types of alcohol.  
For this reason, it is recommend ed that, where allusions are made on 
liqueurs, the legal name ‘liqueur’ should always be supplemented by 
the name of the main raw material used to confer to it its pr edominant 
flavour (e.g. Coconut Liqueur with a shot of Rum; Chocolate Liqueur 
with a hint of Brandy). Otherwise, in presence of allusions, the use of 
the legal name ‘liqueur’, without being supplemented by the name of 
the main flavouring  used, might hint t o an underlying i ntention to 
mislead consumers.  
3.2.4.  Allusions on spirit drinks other than liqueurs  
Article 12(3a) allows the allusion to the name  of one spirit drink (category or 
GI) in the description, presentation and labelling of a spirit drink other than a  
liqueur (i.e. complying with the requirements of any of categories 33 to 40 of 
Annex I), ‘ on condition that:  
(a) the spirit drink referred to in the allusion:  
(i) has been used as the sole alcoholic base for the produc tion of the 
final spirit drink , which shall comply with the requirements of a  
category of spirit drinks set out in Annex I , 
(ii) has not been combined with any foodstuff s other than the 
foodstuffs used for its production or the production of the final 
spirit drink in accordance with Annex I or the  relevant product 
specification, and 
(iii) has not been diluted by addition of water so that its alcoholic 
strength is below the minimum strength provided for under the 
category of spirit drinks set out in Annex I or the product Allusions  
34 specification  for the geographica l indication to which the spirit 
drink referred to in the allusion belongs ; or 
(b)  the spirit drink has been stored for the full maturation period or part of 
it in a wooden cask previously used to mature the spirit drink referred to 
in the allusion, on co ndition that : 
(i) the wooden cask was emptied of its previous contents for those 
categories of spirit drinks or geographical indications for spirit 
drinks for which the addition of alcohol, diluted or not, is 
prohibited , 
(ii) the allusion is made within the descrip tion of the cask used to 
mature the resulting spirit drink,  
(iii)the allusion appears less prominently than the legal name of the 
spirit drink or any compound term used, and  
(iv) by way of derogation from paragraph (4), point (b), the allusion 
appears in a font size  no larger than the font size used for the legal 
name of the spirit drink or any compound term used .’. 
Also in the se cases, according to Article 12(4), point (c), the allusion shall 
‘always be accompanied by the legal name of the spirit drink, which shall 
appear in the same visual field as the allusion. ’ (see § 3.2.5 below) . 
3.2.4.1.  Allusions to spirit drinks used as sole alcoholic base  
Producers may want to create innovative products by experimenting with 
established spirit drink categories or GIs and transforming  them in different 
spirit drink category .  
In specific cases, the legislator allows those producers to make allusion to the 
legal name of the initial spirit drink in the description, presentation and 
labelling of the final spirit drink under the conditions  listed in the previous 
paragraph.  
On the other hand, some spirit drink  categories  – e.g. flavoured vodka – may 
be produced by using another spirit drink category – in the case of the 
example: vodka – as its sole alcoholic base and the producer may have an  
interest in making allusion to that alcoholic ingredient  in the description, 
presentation and labelling of the final product .  
The provisions of Article 12(3a), point (a), of the SDR cover precisely th e 
abov e-mentioned  cases.  
In order to  prevent  the misus e of the reputation of a spir it drink (category or 
GI), the l egislator has provided that any reference to its legal name in the 
description, presentation or labelling of another spirit drink produced by 
using the spirit drink to which allusion is made as its only alcoholic base, is 
only allowed if the final spirit drink complies with the requirements of a 
spirit drink category  and must thus bear the legal name provided for by that 
spirit drink category . 
This implies that it will never  be possible  to make allusion to a spirit drink 
category or GI used as sole alcoholic base on a product generically labelled 
as ‘spirit drink’ . Allusions  
35 Moreover , the prohibit ion to add foodstuffs that are not allowed in the 
production of the spirit drink to which allusion is made or of the final spirit 
drink according to the relevant rules laid down in Annex I for spirit drink 
categories or in the technical file /product specification  for spirit drink GIs , 
excludes any  overlapping  between allusions on spirit drinks and compound  
terms  which require precisely the combination with one or more of such 
foodstuffs (see §  2.1 above).  
Finally, to make allusion to the legal name of a spirit drink in the description 
presentation and labelling of another spirit drink, the alcoholic strengt h of 
the final spirit drink  may not be lower  than the minimum alcoholic strength 
required for the spirit drink to which allusion is made in accordance with the 
rules laid down in Annex I to the SDR for spirit drink categories or the 
relevant technical file /product specification for spirit drink GIs (see examples 
in #31).  
 NB:  The question was raised whether the repetition of the name of a 
spirit drink (category or GI) already indicated in a compound term 
– for instance to describe specific properties of that spirit drink – is 
to be considered as an allusion. The above -mentioned  provisions of 
Article 12(3a), point (a), of the SDR clearly exclude such possibility. 
In that case, the repeated reference to the name of the spirit drink 
used in combination with another foodstuff should be understood as 
an ‘extension’ of the use of that  name in the compound term and 
should comply with the labelling rules laid down in Article 11(3) of 
the SDR. 
#31 - Examples  of permitted  labelling : 
Wine Spirit  (40% vol.)  
Made of Cognac  
Finished in Bourbon Cask  
Since the technical file/ product specification of Cognac does not allow its maturation other than in wooden casks 
having previously contained wine or wine spirits, a Cognac that has been finished in a cask having previously 
contained Bourbon Whisky is no longer entitled to bear that GI na me. However, the allusion to the fact that the 
initial spirit drink has been produced in compliance with the requirements for Cognac until it has been stored in a 
Bourbon cask provides useful information to the consumer.  NB: in that case, the wine spirit s hall have the 
minimum alcoholic strength required for Cognac  (i.e. 40% alcohol by volume).  
Juniper -flavoured Spirit  Drink (32% vol.)  
MADE OF KORN  
According to the requirements laid down in category 19 of Annex I, juniper -flavoured spirit drinks can be 
produced – among others - by flavouring grain spirit  with juniper berries. Since Korn is a grain spirit registered 
as a geographical indication, this labelling is permitted on condition that the  alcoholic strength of the final 
product reaches the minimum required for Korn , (i.e. 32% alcohol by volume), which is higher than the 
minimum alcoholic strength required for juniper -flavoured spirit drinks (i.e.  30% ABV).  
Raspberry Flavoured Vodka (37,5% vol.)  
Made with four -times distilled Vodka  
An Flavoured Vodka, which – according to the requirements laid down in category  31 of Annex I – is  produced 
by adding flavourings and, possibly, sweetening products to a vodka, may make allusion to the vodka used in its 
description, presentation and labelling under Article 12(3a) , point (a),  of the SDR.  NB: The minimum alcoholic 
strength required for flavoured v odka is the same as the alcoholic strength required for vodka, i.e. 37,5% vol.  
#32 - Examples  of forbidde n labelling  (NB: the allusion on a spirit drink that does not correspond 
to a category – and which bears thus the legal name ‘spirit drink’  – is always forbidden ): 
1) Spirit drink  
Made of Rum and Brandy  
The combination of two different spirit drinks may not be labelled as an allusion. If only spirit drinks are part 
of such combination it will have to be labelled as a mixture . If other foodstuffs have been added, the spirit Allusions  
36 drinks names may only be included in a list of ingredients for foodstuffs, provided that the list is in 
accordance with Articles 18 to 22 of the FIC Regulation , as laid down in Article 13(2) of the SDR.  
2) Rum  based  
Spirit Drink  
With spices  
The combination of a spirit drink with one or more foodstuffs other than foodstuffs used for its production 
according to its specific requirements always produces a compound term  and may thus not be labelled as an 
allusion.  
3) Spirit drink  
Obtained from  Rum  (15% vol.)  
Allusions to spirit drink categories or GIs are prohibited where those were simply diluted with water to 
below the required alcoholic strength (37,5% vol. in the case of Rum ). 
3.2.4.2.  Allusions to other spi rit drinks’ casks  
As explained above (see § 1.5), terms referring to the storage of a spirit drink 
for the entire or part of the maturation period in wooden casks previously 
used to mature another spirit drink cannot be considered as a voluntary 
information within the  meaning of Article 36 of the FIC Regulation due to 
the pro vision  laid down in Article 10(7) , first subparagraph,  of the SDR 
prohibiting the use of spirit drinks names in the description, presentation or 
labelling of any beverage not complying with the req uirements laid down in 
the SDR or the relevant GI techni cal file/product specification.  
The only exceptions allowed to that prohibition relate to the labelling of 
compound terms, allusions and ingredients list, as regulated by Articles 11, 
12 and 13(2) to (4) of the SDR. Therefore, the reference to a spirit drink in 
whose wooden cask another spirit drink has subsequently been matured is 
not only a voluntary information according to the FIC, but also an allusion 
regulated by Article 12(3a) of the SDR.  
 NB:  Article 12(3a), point (b), letter (i), of the SDR, requires for those 
spirit drinks (categories or GIs) for which the addition of alcohol, 
diluted or not, is prohibited, t o empty the wooden cask of its 
previous contents. This requirements applies e.g. to spirit drink 
categories 1 -14. For spirit drink categories or GIs for which the 
above requirement does not apply, it is therefore not prohibited to 
leave in the wooden cask some of the spirit drink that had previously 
been matured in it . However, such pract ice, where used , would  need 
to be properly labelled in accordance with Article 13(3) or (4) of the 
SDR (i.e. the labelling provisions for mixtures ) in addition to  the 
labelling provisions laid down in Article 12(3a), point (b) , letters 
(ii) to (iv) , of the  SDR, for allusions to spirit drinks casks  (see 
example 3 in #33) .                                                                                                                                                                                                                                                                       
 NB:  According to Article 12(3a), point (b), letters (ii) to (iv), of the SDR, 
and in derogation to the general labelling rule applicable to 
allusions on alcoholic beverages (i.e. t hat the allusion shall appear 
in a font size which is no larger than half the font size used for the 
name of the alcoholic beverage or possible compound terms used), 
the allusion to spirit drink casks may appear in a  font size which is 
no larger  than the f ont size used for the legal name of the spirit 
drink or any compound term used, as long as it clearly refers to the 
cask used to mature the resulting spirit drink and that it appears in 
a less prominent  way than the legal name of the spirit drink or any Allusions  
37 compound term used. However, spirit drinks referred to in that 
provision that were labelled before  31 December 2022 in 
application Article 4 of Implementing Regulation (EU) No 716/2013 
(i.e. merely requiring that the allusion appear s in a font size smaller  
than those used for the sales denomination and the compound term) 
may continue to be placed on the market until stocks are exhausted. 
In any case, even during this transitional period, it is recommended  
that the allusion to spirit drink casks is not label led in a more 
prominent way than the legal name of the spirit drink (e.g. by using 
a different background, colours or character type ).                                                                                                                                                 
Other than the aspects that need to be assessed by t he national competent 
authorities concerning the correct use of references to the maturation in 
wooden casks previously used to mature  other alcoholic beverages (notably 
wine  or bee r) listed under § 1.5 above , including the compliance with Article 
7(1) of the FIC Regulation , for allusions to spirit drinks ’ casks it is 
recommended  that: 
1) the spirit drink has indeed been matured in a wooden cask  previously 
used to mature  the spirit drink  to which allusion is made : in fact, 
maturation as defined by Article 4 , point (11), of the SDR, entails ‘the 
storage of a spirit drink in appropriate receptacles for a period of time for 
the purpose of allowing that spirit drink to undergo natural re actions that 
impart specific characteristics to that spirit drink ’. This means, for 
example, that the use of inert containers such as plastic drums or the use 
of wood chips as a substitute for maturation in a wooden cask, are not 
permitted;  
2) for those categ ories of spirit drinks which prohibit the addition of alcohol 
(e.g. categories of spirit drinks 1 to 14 of Annex I, as provided for in 
Article 7(2) , point (b), of the SDR), casks  used for maturation  are 
emptied  of their previous contents;  
3) since the cask us ed to mature a spirit drink has a significant effect on its 
character, it is legitimate to provide consumers with information on the 
previous contents of the cask used. However, such information must be 
clear and unambiguous , it shall refer to the cask used and not mere ly to 
the spirit drink previously matured  in it and shall not mislead the 
consumer as provided for by Articles 7(1a), 7(2) and 36 of the FIC 
Regulation. For example:  
a) reference to a particular cask can only be jus tified if the spirit drink 
has been matured in the cask for a long enough period  to affect the 
organoleptic character of that spirit drink;  
b) the context in which reference is made to the allusion should be made 
clear and should only be for the purpose of in forming the 
consumer  of the previous contents of the cask used , i.e. that the spirit 
drink has spent a sufficient amount of time in a cask which had been 
previously use to mature , for example, rum;  
c) the allusion must be accurate and  not misleading . The labe lling and 
marketing of a product should not suggest that all the spirit drink has 
been matured in the type of cask claimed when that is not the case. It 
would be misleading to describe a whisky as, for example, ‘Rum cask Allusions  
38 matured ’, if only a proportion of the barrels used to produce the 
whisky  have been matured in rum casks;  
d) some spirit drinks use the term ‘ finishing ’ or ‘finish ’. This is a 
traditional industry term which refers to the final period of maturation 
in a cask which is different to the cask prev iously used.  As finishing 
corresponds to part of the maturation period, the requirements 
referred to above should apply equally to finishing.  
#33 - Examples of permitted labelling : 
1) RUM 
Matured in Kentucky Bourbon barrels  
2) Single Malt Whisky*  
Matured in Cognac barrel / Rum Cask Finish  
3)  Spirit Drink  
Mixture of Gin 95% & Rum 5%   
Matured in Rum Cask  
could indicate that the Ru m/Whisky /Gin & Rum  have spent in a wooden barrel/cask previously used 
to mature Bourbon/Cognac/Rum sufficient time to have an effect on their organoleptic character.  
*According to point 2(a)(iii) of Annex I (whisky or whiskey), the maturation of the final distillate shall b e carried out in wooden 
casks not exceeding 700 litres capacity. Since the type of wooden cask is not specified, it is possible to reuse casks in whi ch other 
alcoholic beverages were previously matured in order to confer particular organoleptic characteris tics to the whisky/whiskey.  
#34 - Examples  of forbidden labelling : 
Cognac  
Finished in R um Wood  
is not allowed because the GI technical file/ product specification of Cognac does not provide the 
finishing in a cask not previously used to mature wine or wine spirits in its producing method . 
Whisky  
Matured in Brandy Barrel  
is not allowed because the allusion may not be more prominent than the legal name of the spirit 
drink and the font size used for the allusion may not be larger than that used for the legal name.  
Cognac Finish  
Rum  
is not allowed because the allusion must include reference to the type of cask used.  
3.2.5.  Other  labelling rules for allusions  
Article 12(4) provides that ‘ the allusions  referred to in paragraphs 2, 3 and 3a  
shall : 
(a) not be on the same line as the name of the alcoholic beverage;  
(b) appear in a font size which is no larger than half the font size used for the 
name of the alcoholic beverage and, where compound terms are used, in a 
font size which is no larger than half the font size used for such compound 
terms, in accordance with point (c) of Article 11(3); and  Allusions  
39 (c) in case of allusions in the description, presentation and labelling of spirit 
drinks, always be accompanied  by the legal name of the spirit drink , 
which shall appear in the same visual field as the allusion.’28 
The provisions laid down in Article 12(4) are thus mandatory when allusions 
are made on alcoholic beverages but not when allusions are made on 
foodstuffs  other than alcoholic beverages ( Article 12, paragraph 1) . For those 
(e.g. rum ice cream, Kirschpralinen, Egg liqueur cake) , the general labelling 
rules of the FIC Regulation are of application and in particular Article 7 on fair 
information practices . 
Moreover, when allusions to spirit drinks are made on alcoholic beverages  
other than spirit drinks and on liqueurs , the proportion of the alcohol  
represented by each alcoholic ingredient is to be indicated at least once : in the 
same visual field as the all usion and in descending order of quantities used.  
#35 - Examples  of permitted labelling of allusions  on alcoholic beverages:  
        Beer   
with a splash of Genever  
7% VOL. (Beer 9 0% - Genever 10 %) : alcohol proportion  
 
Apple Cider   
with Punch au Rhum  
Alcohol 20% Vol. ( Apple Cider 95% - Rum 5%) : alcohol proportion  
 
 
 
 
   
 
 
 
 
        
 
 
 
 
           
 
 
 
 
 
 
 
 
 
 
 Alcoholic Beverage  
Diplomat Cocktail  
with Cognac & Maraschino  
15% Vol. (Wine 75% - Cognac 10% - Maraschino  8% - Ethyl alcohol  of agricultural 
origin  7%) : alcohol proportion  
    Chocolate Liqueur  
                      with a shot of Gin  
alc. 16% vol. (Ethyl alcohol of agricultural origin 96% - Gin 
4%) : alcohol proportion  
LIQUEUR  
Egg liqueur & cinnamon  
with Brandy and Irish Whisk ey 
17% VOL. (Ethyl alcohol of agricultural origin 88% - Brandy 7% - Irish Whisk ey 5%) 
: alcohol proportion  
                         Crème de Brandy   
                                                 
28  Introduced by Commission Delegated Regulation (EU) 2021/1334 of 27 May 2021 amending 
Regulation (EU) 2019/787 of the European Parliament and of the Council as regards allusions to 
legal names of spirit drinks or geographical indications for spirit  drinks in the description, 
presentation and labelling of other spirit drinks  (OJ L 289, 12.8.2021, p. 1) . Allusions  
40  
 
 avec Rhum  
ALCOHOL 30% VOL. (Brandy 90% - Rum  10%) : alcohol proportion  
Wine Spirit  
Made of C OGNAC  VSOP  
and matured in Bourbon Cask  
this is a double allusion : first to a spirit drink (Cognac) used as sole alcoholic base for 
the production of a different spirit drink (Wine Spirit) . In fact, the initial spirit drink does 
no longer comply with the requirements laid down in its GI technical file/ product  
specification because it has been matured in a wooden cask having previously contained 
Bourbon Whisky (second allusion), which is not allowed for Cognac  
#36 - Examples  of forbidden labelling : 
Spirit drink  
Finished in COGNAC  cask 
Although allowed as such, in this case this labelling  does not comply with the labelling provision laid 
down in Article 12( 3a), point (b), letter s (iii) and  (iv), of the SDR requiring that the allusion appear s 
less prominently than the legal name of the spirit drink or any compound term used and in a font size 
no larger than the font size used for the legal name of the spirit drink or any compound term used29. 
In any case such labelling would represent an unfair presentation as it emphasizes an allusion 
(Cognac indicated in a too prominent way) at the expense of the legal name of the product (spirit 
drink), which could be considered as misuse of a spirit drink GI . 
In the above examples, the na me of the foodstuff (beer , apple cider, 
aromatised wines, chocolate liqueur, crème de brandy, liqueur , wine spirit ) and 
the compound terms (crème de brandy – which may be both a compound term 
and the legal name –, chocolate liqueur and egg liqueur & cinnam on) are not 
on the same line as the allusion ( Genever, P unch au Rhum, Cognac, 
Maraschino, Gin, Brandy , Irish Whisky , Rum, Bourbon cask ). 
In any case, when the resulting beverage is a spirit drink, its  legal name shall 
always be indicated in the same visual  field where appears the allusion, which 
shall be written in a font size which is half the font size  used for the legal 
name of the spirit drink and of the possible compound term , or smaller  
(except for allusions to spirit drinks’ casks, which can be displayed in a font 
size no larger than th e font size used for the legal name of the spirit drink and 
possible compound terms) . 
The allusion may however appear in characters  that are of a differe nt font and 
colour or against a different background than the name of the alcoholic 
beverage/compound term.  Nevertheless, it is recommended  that the allusion 
is displayed in a less prominent  way than the name of the alcoholic beverage. 
This recommendation becomes a legal obligation  for allusions to spirit 
drinks’ cask s, so as to balanc e the less restrictive font size requirement 
provided for those allusions . 
3.3. Allusion to ‘imitation ’ spirit drinks flavourings  
As already mentioned (see § 1.3. above),  according  to Article 10(7),  first 
subparagraph , a spirit drink name  (category or GI) may not be used  in any 
way whatsoever on the (description), presentation and labelling of any 
                                                 
29  Article 12(3a), point (b), letter (iv), of Regulation (EU) 2019/787 only applies as of 31 December 2022. In 
the meantime, Article 4 of Implementin g Regulation (EU) No 716/2013 (requiring that allusion shall appear 
in a font size smaller than those used for the sales denomination and the compound term) remains of 
application.  Allusions  
41 beverage  that does not comply with the production requirements laid down in 
the respec tive spirit drink category or GI technical file/product specification.  
This strict prohibition includes explicitly also the cases where it is clearly 
stated on the (description), presentation and labelling that it is an imitation by 
using terms such as ‘li ke’, ‘type’, ‘style’ , ‘made’, ‘flavour’, etc.  
The name of a  spirit drink (category or GI) may not be used to 
(describe), present or label a beverage different from that spirit drink . 
This prohibition is obviously  without prejudice to the provisions laid down for 
compound terms (Article 11), allusions (Article 12)  and list of (alcoholic) 
ingredients (Article s 13(2)  to (4)), which of course apply provided that all the 
relevant rules are complied with.  
#37 - Examples  of forbidden labelling :  
1) Vodka -flavoured alcoholic beverage  
2) Spirit drink aromatised with Rum  
3) Brandy -style drink  
4) Gin-type low -alcohol beverage  
5) Whisky -like alcohol free beverage  
Nonetheless, by introducing Article 10(7) , second subparagraph , the legislator 
has decided that – whereas it is clear that, in order not to risk misleading the 
consumer, the name of a spirit drink (category or GI) may not be used to 
describe a beverage that does not comply with its requirements – the names of 
spirit d rink categories  may be used as:  
1) part of the reference to a flavouring , or 
2) in the presentation and labelling of foodstuffs other than beverages  
produced by using those flavourings,  
even if those products do not comply with the requirements laid down for the  
spirit drink category they refer to in their presentation and labelling.  
The legislator acknowledged thus a common practice on the market, whereas 
certain flavourings bear the name of spirit drink categories (e.g. rum flavour or 
brandy flavouring) althoug h they are not in compliance with the requirements 
of those categories, which however is not bound to mislead the consumer.  
Nonetheless, in order to confer more stringent protection to GIs, in Article 
10(7) , second subparagraph , the legislator has explicit ly forbidden that the 
names of geographical indications  for spirit drinks be used to describe any 
flavourings or foodstuffs fla voured with those flavourings.  
#38 - Examples  of allusions to (‘imitation’) spirit drinks : 
1) Babà al rum – Babà au rhum  – Rum baba : in this case, only real rum  (compliant with all 
requirements of category 1 of Annex I) shall be used  
2) Babà aromati sé au rhum – Babà con aroma di rum – Babà with rum flavour – Rum flavoured 
babà:  In this case, rum flavour  may be used, provided that the consumer is not misled about the 
nature of the flavouring used ( i.e. not a spirit drink)  
Other examples : 
NON -LIQUID FOODSTUFFS  
3) Rum -flavour ice cream may contain a flavour  
4) Ice-cream with Armagnac must contain authentic Armagn ac (GI)  
5) Gin & tonic flavoured yogurt may  contain a flavour  Allusions  
42 6) Scotch Whisky flavoured chocolate must contain authentic Scotch Whisky (GI)  
LIQUID FOODSTUFFS (BEVERAGES)  
7) Orange juice with rum  & vodka  must contain  authentic  rum and vodka  
8) Coke flavoured with Irish Whiskey must contain  authentic Irish Whiskey (GI)  
9) Rum refined  beer must contain  authentic rum 
10) Genever  refined  beer must contain  authentic Genever  (GI) 
11) Egg liqueur with a scent of Kirschwasser must contain  authentic Kirschwasser  
12) Egg liqueur with a scent of Cognac must contain  authentic Cognac (GI)  
 NB: The above examples  are descriptive  and do not apply the labelling provisions requiring that the allusion 
shall appear on a separate line as the legal name of the liqueur and in a font size which is no larger than half 
the font size used for the latter.  
3.4. Low /zero-alcohol beverages  referring  to spirit drinks ’ names  
As already mentioned (see § 1.3 and 3.3  above),  Article 10(7), first 
subparagraph, of the SDR prohibits the use of legal names of spirit drink 
categories or geographical indications for spirit drinks  in the description, 
presentation and labelling of any beverage  not complying with the 
requirements of the relevant spirit drink category or GI. That prohibition also 
applies where such legal names or geographical indications are used in 
conjunction with w ords or phrases such as ‘like’, type’, ‘style’, ‘made’, 
‘flav our’ or any other similar term.  
 NB: Such prohibition extends also to phantasy names or references such as 
e.g. ‘no Gin’, ‘for Gin lovers’, ‘VirGin’, ‘Ginfection’ to describe 
beverages not compl ying with the requirements laid down in category 
20 of Annex I to the SDR. 
#39 - Examples  of forbidden labelling (because referring to spirit drinks while claiming that the 
beverage does not contain any alcohol) : 
1) Non-alcoholic Spirit Drink   – or –       Alcohol -free Spirit Drink  
2) Zero alcohol Gin                   – or –       Zero alcohol Gin-Tonic 
3) Non-alcoholic Whisky          – or –       Non-alcoholic Whisky & Coke  
The provisions governing compound terms and allusion are listed among the 
exceptions to  above -mentioned prohibition. However , the reference to the name 
of a spirit drink in a beverage containing no alcohol would not be possible  
under  either  compound terms or allusions  rules due to the condition that all the 
alcohol in the final product must originate fro m the spirit drink referred to.  
In fact, if the final beverage  does not contain any alcohol at all, the spirit drink 
referred to may not reasonably be expected to compl y with all requirements 
(notably the minimum required alcoholic strength) of the spirit drink category or 
geographical indication whose name has been used on the label.  
Any beverage referring to a spirit drink name  (be it in a compound 
term or an allusion)  is always an alcoholic beverage . 
In this context, it is worthwhile underlin ing that the term ‘alcoholic beverage’ is 
not defined in the EU legislation , although, for its own purposes, the Union 
Customs Code classifies as ‘non-alcoholic ’ beverages with an alcoholic strength Allusions  
43 by volume not exceeding 0.5 % , while beverages with more than 0.5% alcohol 
by volume are classified as alcoholic beverages30. 
As far as the FIC is concerned, its Articles 16(4) and 28(2) refer to alcoholic 
beverages containing more than 1. 2% by volume of alcohol  not with the 
purpose to define what an alcoholic beverage is but merely to determine the 
alcoholic beverages (i.e. those containing more than 1 .2% by volume of 
alcohol) that are respectively exempted from the mandatory indica tion of the 
nutrition declaration and the list of ingredients  or required to indicate the actual 
alcoholic strength  on the label . 
However, i n the absence of a definition of ‘alcoholic beverage’ in the  EU food 
legislation , and specifically for the purposes of compound terms or allusions to 
the name of spirit drinks on the label of other foodstuffs , resulting  drinks  
containing 1 .2% by volume of alcohol or less are still to be considered as 
alcoholic beverages  in the context of the SDR . 
Nonetheless, as referre d to in Article 38(2) of the FIC Regulation, Member 
States may adopt national measures concerning matters not specifically 
harmonised by this Regulation provided that they do not prohibit, impede or 
restrict the free movement of goods that are in conformit y with this Regulation. 
Of course, such national measures shall not authorise practices which may  be 
misleading to the consumer.  
It should be further noted that in recent years we have observed a tendency of 
increasing marketing of partially or totally dea lcoholized beverages. This is 
notably the case of beer, which is a product that is not regulated at EU level.  
Legitimately, in the absence of EU rules in this respect, and in view of 
providing appropriate information to consumers, Member States may adopt 
provisions to determine the alcohol content thresholds that may trigger 
definitions such as ‘non -alcoholic’, ‘low -alcohol’, ‘de -alcoholised’ on 
beverages that are not regulated at EU level.  
This excludes obviously the use of such terminology on spirit drink s, wine31 and 
aromatised wine products, which are subject to specific provisions at EU level.  
However , other beverages, such as beer  or alcopops , i.e. drinks resulting from 
the combination of any beverage with spirit drinks (which is the case of certain 
allusions, as defined by Article 3 , point (3)(a) , and regulated by Article 12(1) 
and (2) of the SDR ) may benefit of such national definitions (where they exist).  
Consequently, the labelling of a beverage as for example:  
 ‘vodka & orange  (compound term)  
non-alcohol ic beverage ’ - with 0,05% alcohol by volume , 
is not allowed  under EU law32. 
                                                 
30 Annex I to Council Regulation (EEC) No 2658/87 on the tariff and statisti cal nomenclature and 
on the Common Customs Tariff : Text of Note 3 of the Chapter 22: ‘ 3. For the purposes of 
heading 22.02, the term ‘non -alcoholic beverages ’ means beverages of an alcoholic strength by 
volume not exceeding 0.5 % vol. Alcoholic beverages a re classified in headings 22.03 to 22.06 
or heading 22.08 as appropriate. ’ 
31  Provisions on ‘dealcoholized’ or ‘partly dealcoholized’ wines are currently under discussion in 
the framework of the revision of the CMO Regulation (EU) No 1308/2013.  Allusions  
44 On the other hand, given that beer is not regulated at EU level, the following 
labelling could be allowed by national legislation  (where it exists) : 
 ‘no-alcohol  beer 
with a shot of gin (allusion) - with 0,4% alcohol by volume , or as  
 ‘low-alcohol  beer 
refined with rum’ (allusion) - with 1% alcohol by volume . 
In 2021, the Commission will launch a tender for a study to further examine the 
above issues  in view of determini ng whether specific legislation is needed . 
3.5. Checks  
Checks on the (description), presentation and labelling of a product containing 
an allusion to the name of a spirit drink (category or GI) address the compliance 
with following conditions:  
3.5.1.  On foodstuffs other than alcoholic beverages  
Production : 
1. the foodstuff making allusion to the spirit drink (s) is a foodstuff (liquid 
or not) other than an alcoholic beverage (i.e. that does not contain any 
alcohol ); 
2. the resulting  product is a n alcoholic  beverage or a no n-liquid foodstuff  
containing alcohol, even if only traces ; 
3. the spirit drink (s) referred to in the allusion compl y/ies with all 
requirements laid down for its /their  production in the relevant spirit 
drink category of Annex I or GI technical file/product sp ecification, 
including its /their  minimum alcoholic strength , i.e. only authentic spirit 
drinks may be referred to in an allusion ; and 
4. all the alcohol in the resulting product originates from the spirit 
drink (s) referred to in the allusion  (except for the alcohol that may be 
present in flavourings, colours o r other authorised ingredients used for 
the production of the initial foodstuff).  
Labelling:  
5. in case of liquid foodstuffs, allusions are only possible to more than 
one spirit drink (the combination of one spirit drink with other 
foodstuffs being  subject to the rules on compound terms);  
6. the final product is labelled in compliance with the provisions of the 
FIC Regulation . 
3.5.2.  On alcoholic beverages other than  spirit drinks  
Production:  
                                                                                                                                          
32  In fact,  such beverages would contain a certain amount of alcohol , albeit a very low percentage. 
Therefore, under EU law, they would have to be considered as alcoholic beverages.  Allusions  
45 1. the foodstuff making allusion to the spirit drink(s) is an alcoholic 
beverage other than a spirit drink (e.g. wine, aromatised wine product, 
beer, cider, perry, other fermented beverages);  
2. the resulting  product is still an alcoho lic beverage;  
3. the spirit drink (s) referred to in the allusion compl y/ies with all 
requirements laid down for its /their  production in the relevant spirit 
drink category of Annex I or GI technical file/product specification, 
including its /their  minimum alcoh olic strength , i.e. only authentic 
spirit drinks may be referred to in an allusion ; 
4. all the added alcohol originates from the spirit drink (s) referred to in 
the allusion (i.e. in addition to the alcohol naturally present in the 
initial alcoholic beverage),  with the exception of the alcohol that may 
be present in possible flavourings, colours or other authorised 
ingredients.  
Labelling:  
5. possible allusions on wine and aromatised wine products must 
comply with the specific EU legislation for those products;  
6. the name of the alcoholic beverage must be displayed in a 
conspicuous way so as to be easily visible, clearly legible and, where 
appropriate, indelible. It shall not in any way be hidden, obscured, 
detracted from or interrupted by any other written or pictori al matter 
or any other intervening material;  
7. the allusion is not on the same line as the  name of the alcoholic 
beverage;  
8. the allusion appear s in a font size which is no larger than half the font 
size used for the name of the alcoholic beverage and  of the compound 
terms , where compound terms  are used ; and  
9. the proportion of each alcoholic ingredient is indicated at least once: 
in the same visual field as the allusion  and in descending order of the 
quantities used. That proportion is equal to the percentage b y volume 
of pure alcohol it represents in the total pure alcohol content by 
volume of the final product.  
3.5.3.  On liqueurs  
Production:  
1. the foodstuff making allusion to the spirit drink(s) is a liqueur , i.e. a 
spirit drink complying with the requirements of any o f categories 33 
to 40 of Annex I to the SDR (liqueurs);  
2. the resulting  product is still a liqueur , i.e. a spirit drink complying 
with the requirements of category 33 of Annex I (liqueur) ; 
3. the spirit drink (s) referred to in the allusion comply /ies with all 
requirements laid down for its /their  production in the relevant spirit 
drink category of Annex I or GI technical file/product specification, 
including its /their  minimum alcoholic strength , i.e. only authentic 
spirit drinks may be referred to in an allusion ; Allusions  
46 4.   all the added alcohol originates from the spirit drink (s) referred to in 
the allusion (i.e. in addition to the alcohol naturally present in the 
initial liqueur), with the exception of the alcohol that may be present 
in possible flavourings, colours or other authorised ingredients.  
Labelling:  
5. the legal name is ‘liqueur’ as the resulting  spirit drink still compl ies 
with the relevant requirements of category 33 of Annex I  or one of 
the legal names provided for by the other liqueur category whose 
requirements it complies with ; 
6. the legal name of the liqueur  must be displayed in a conspicuous way 
so as to be easily visible, clearly legible and, where appropriate, 
indelible. I t shall not in any way be hidden, obscured, detracted from 
or interrupted by any other written or pictorial matter or any other 
intervening material;  
7. the allusion is always accompanied by the legal name of the liqueur, 
which shall appear in the same visual  field33; 
8. the allusion is not on the same line as the legal name of the liqueur;  
9. the allusion appear s in a font size which is no larger than half the font 
size used for the legal name of the liqueur  and of the compound 
terms , where compound terms  are used ; 
10.  the term ‘ cream ’ (in English only) does not appear either in the legal 
name of the liqueur nor in the legal name of the spirit drink(s) 
referred to in the allusion; and  
11. the proportion of each alcoholic ingredient is indicated at least once: 
in the  same visual field as the allusion and in descending order of the 
quantities used. That proportion is equal to the percentage by volume 
of pure alcohol it represents in the total pure alcohol content by 
volume of the final product.  
3.5.4.  On spirit drinks other t han liqueurs  
Production:  
1. the foodstuff making allusion to the ( one) spirit drink  is a spirit drink 
other than a liqueur , 
2. in that case the allusion can occur in the two following case s: 
a. that the spirit drink referred to in the allusion  has been used as 
the sole alcoholic base  for the production of the final spirit drink 
on condition that : 
i. no other spirit drinks or ethyl alcohol or distillates have been 
added  (which would rather be subject to the provisions on 
mixtures) and that the final spirit drink complies with the 
requirements laid down in Annex I for a spirit drink category 
                                                 
33  Liqueurs falling under this provision which do not meet this requirement but which  meet the 
requirements of Regulation (EC) No 110/2008 and were produced and labelled before 31 
December 2022 may continue to be placed on the market until stocks are exhausted.  Allusions  
47 and bears thus the legal name of that category (and never the 
generic name ‘spirit drink’);  
ii. the spirit drink referred to in the allusion has not been 
combined with any foodstuffs other than the foodstuffs used 
for its production or for the production of the final sp irit 
drink in accordance with Annex I or the relevant product 
specification (which would rather be subject to the 
provisions on compound terms); and  
iii. the final spirit drink has not been diluted by addition of 
water so that its alcoholic strength is below th e minimum 
strength provided for under the relevant category of spirit 
drinks set out in Annex I or the product specification  for the 
geographical indication to which the spirit drink referred to 
in the allusion belongs ; OR 
b. the spirit drink has been stored for the full maturation period or 
part of it (e.g. ‘finishing’) in a wooden cask previously used to 
mature the spirit drink referred to  in the allusion, on condition 
that:  
i. the wooden cask was emptied of its previous contents for 
those categories of spirit  drinks or geographical indications 
for spirit drinks for which any addition of alcohol is 
prohibited,  
ii. the spirit drink has been matured in the cask for a long 
enough period to affect its organoleptic character;  
iii. the allusion is only for the purpose of info rming the 
consumer of the production process and the previous 
contents of the cask used;  
iv. the allusion is accurate and not misleading: the labelling and 
marketing of a product should not suggest all the spirit has 
been matured in the type of cask claime d when that is not the 
case (e.g. when only part of the spirit drink has been matured 
in casks previously used to matured other spirit drinks).  
Labelling:  
3. the legal name of the spirit drink must be displayed in a conspicuous 
way so as to be easily visible, clearly legible and, where appropriate, 
indelible. It shall not in any way be hidden, obscured, detracted from 
or interrupted by any other written or pict orial matter or any other 
intervening material;  
4. the allusion is always accompanied by the legal name of the spirit 
drink, which shall appear in the same visual field34; 
5. the allusion is not on the same line as the legal name of the spirit 
drink;  
                                                 
34  Spirit drinks which do not meet this requirement but which meet the requirem ents of Regulation 
(EC) No 110/2008 and were produced and labelled before 31 December 2022 may continue to be 
placed on the market until stocks are exhausted.  Allusions  
48 6. in case of allusions to spirit drinks used as sole alcoholic base : the 
font size used for the allusion is no larger than half the font size used 
for the legal name of the spirit drink  and for the compound term(s) , 
where compound terms are used35; 
7. in case of  allusions to a spirit drink cask : 
a. the allusion must refer to the type of cask used ( a mere reference  
to the spirit drink previously contained in it is not admissible);  
b. the allusion must appear in a less prominent way than the legal 
name of the spirit drin k; 
c. the font size used for the allusion is no larger than half the font 
size used for the legal name of the spirit drink and of the 
compound term (s), where compound terms are used36; and 
d. in case of spirit drinks for which addition of alcohol is allowed, if 
the cask is not emptied and some of the previous spirit drink is 
intentionally left  in it to be combined with the other spirit drink, 
the resulting product must be labelled according to the provisions 
for mixtures, which may be supple mented by the allusion to the 
spirit drink that had been previously contained in the cask itself . 
3.5.5.  On ‘imitation’  flavourings  
1. Spirit drinks names (both categories and GIs) are used exclusively : 
a. to describe, present or label a spirit drink complying with the 
requirements of the relevant category or GI; or  
b. in a compound term, allusion, ingredients list, mixture or blend in 
compliance with the relevant provisions.  
2. Exception : the legal name of a s pirit drink category (not a GI name) 
has been used to define:  
a. a flavouring, or  
b. a foodstuff other than a beverage flavoured with that flavouring,  
even if those do not meet the provisions for allusions, provided that 
such legal names are supplemented by the term ‘flavour’ or any other 
similar term.  
3.5.6.  Allusions to GIs 
Besides the recommenda tion that no ‘comparable ’ ingredients should be 
used (except for other spirit drinks, in compliance with the provisions on 
allusions), any allusion  to a spirit drink with geographical indication 
                                                 
35   Spirit drinks falling under this provision and that were labelled in compliance with Article 4 of 
Implementing Regulation (EU) No 716/2013 before 31 December 2022 may continue to be 
placed on the market until stocks are exhausted.  
36  Spirit drinks falling under this provision and that were labelled in compliance with Article 4 of 
Implementing Regu lation (EU) No 716/2013 before 31 December 2022 may continue to be 
placed on the market until stocks are exhausted.  Allusions  
49 should also comply with the condition that the taste is recog nizable  and 
attributable primarily to that GI . 
This latter requirement renders checks particularly cumbersome as it  is 
already quite difficult to control  the presence of authentic  whisky or 
apricot spirit  in foodstuffs such as cake, chocolate  or yogurt , but it is even 
more difficult to check analytically and organoleptically if for example  the 
whisky is Scotch Whisky  or the apricot spirit is Kecskeméti barackpálinka . 
It is recommended  to focus checks on the documentation that can be 
found at production premises during  on-the-spot check s: the producer of 
foodstuffs such as cake, chocolate, etc. (in the above examples) can be 
asked to identify the supplier of the GI spirit drinks and provide receipts 
and documentation.  
There may also be a specific agreemen t with the supplier relating to the 
authenticity of the product. The presence of such documentation may 
contribute to proving authenticity. However, the absence of supplier 
documentation does not necessarily indicate a fraud but may be grounds 
for making f urther enquiries . 
If the paper traceability exercise does not provide sufficient guarantees 
and there are still doubts, analytical tests can be used.  
Depending on the case, it could be  appropriate to apply  the isotopic mass 
spectroscopy analysis and use is otopic database s as a reference.  
#40 – Examples : 
In the control seminar organised by DG AGRI in 2018, an example was presented on how it 
could be checked if vodka has been produced in Poland or Sweden using the isotopic values of 
the water used, as they ar e different in the north part.  
In case of ‘Kecskeméti barackpálinka ’, apricots are used, and they might give a specific pattern 
which could be traced when the isotopic analysis is carried out.  
Of course such analyses might seem complex but this is just a possible 
method to identify the product and they are not a systematic requirement. 
It is up to the competent authority to ide ntify the best tool to be used.   Mixtures  
50 4. MIXTURES  
Article 3, points (9) and (10) Definition s 
Articles 13(3) and (4) Conditions for use and  labelling provisions  
4.1. What are mixtures  
Under certain conditions, the names of spirit drink (categories or GIs) may be 
indicated in the description, presentation and labelling of spirit drinks that 
have been produced by combining d ifferent alcoholic ingredients.  
According to Article 3 , point (10), ‘ 'mixture' means a spirit drink that has 
undergone mixing ’, whereas according to Article 3, point (9) ‘'to mix' means  to 
combine a spirit drink that either belongs to a category of spirit drinks set out 
in Annex I or to a geographical indication with one or more of the following:  
(a) other spirit drinks which do not belong to the same category of spirit 
drinks set out in Annex I;  
(b) distillates of agricultural origin;  
(c) ethyl alcohol of agricultural origi n.’ 
Mixtures  are spirit drinks  resulting from the combination of different 
alcoholic components  (i.e. spirit drinks, distillates, ethyl alcohol)  
Other foodstuffs may be added exclusively through their use as ingredients in 
the production of one or more sp irit drinks composing the mixture.  
The typical example of such spirit drinks through which other foodstuffs are 
added is represented by liqueurs that, according to the requirements of spirit 
drink category 33, may be produced by adding sweetening products,  
flavourings, products of agricultural origin or foodstuffs to ethyl alcohol of 
agricultural origin, distillates of agricultural origin, one or more spirit drinks or 
a combination thereof.  
Through the addition of a liqueur to a mixture, all ingredients use d to produce 
that liqueur are also introduced into the mixture itself.  
#41 - Examples  of permitted mixtures : 
1) Angel Face cocktail (Gin, Apricot Brandy, Calvados)     
2) Grand Marnier  Liqueur * (Orange liqueur & Cognac)  
3) B & B cocktail (Cognac & Bénédictine = herbal liqueur ) 
4) Black Nail cocktail (Irish Whisky & Irish Mist ) 
*The reference to a brand name is made here solely for illustrative purposes (Grand Marnier being a renowned 
liqueur with a well -known composition in terms of alcoholic ingredients).  
 NB: Mixtures of two specifically defined spirit drink categories  other than 
liqueurs  – e.g. of a grain brandy (category 3 of Annex I, which requires 
a minimum alcoholic strength by volume of 35 %) and a Williams 
(category 9 of Annex I, which requires a minimum  alcoholic strength 
by volume of 37 .5 %) – should  have an actual alcohol content 
corresponding to the calculated combined minimum alcohol content of 
the two, i.e. for example 36.5% vol. In fact, where water or other Mixtures  
51 liquids are added so that the alcoholic strength of any spirit drink is 
below the minimum strength provided for under the relevant spirit 
drink category set out in Annex I, that spirit drink can no longer use 
any of the names laid down in the respective category as legal name, 
whether one or mor e spirit drink categories are indicated in the 
description, presentation and labelling of the final product . The same 
applies if flavourings, colours or sweetening products are added in 
breach of the requirements laid down for the respective spirit drink 
category . In that case the final beverage would not represent a mixture 
in the sense of Article 3 , points (9) and (10) , and could not be labelled 
as such in accordance with the labelling rules for mixtures , and the 
names of the spirit drinks used could only be included in a list of 
ingredients as provided by Articles 18 to 22 of the FIC Regulation . 
 NB: For the purpose of the SDR, only cocktails resulting exclusively from a 
combination of different categor ies of spirit drinks, distillates of 
agricultural origin and/or EAAO  can be considered as mixtures and 
labelled as such. Moreover, the conditions of use and labelling 
provisions on mixtures are only relevant for pre -packed drinks. 
Nonetheless, it should be  pointed out that, in some ready -to-drink 
cocktails recipes, liqueurs may incorporate for instance the sugar and 
foodstuffs ( e.g. fruit juices/milk products) needed for realising the 
cocktail. In that case, the cocktail could still be considered and 
labell ed as a mixture, on condition that the liqueur(s) used comply with 
the requirements laid down in spirit drink category 33 (notably the 
minimum alcoholic strength and minimum sugar content) and that the 
resulting beverage is still a spirit drink, e. g. has a  minimum alcoholic 
strength of 15% by volume.  
4.2. Conditions of use and labelling provisions  
4.2.1.  General rules  
Article 13(3) provides for the general condition of use and labelling for 
mixtures . 
In order to protect spirit drink names (categories or GIs) from undue  
misappropriation, Article 13(3) , first subparagraph,  provides that, in the case 
of mixtures, those names ‘ may be indicated only in a list of the alcoholic 
ingredients appearing in the same visual field as the legal name of the spirit 
drink ’. 
The legal name  will be ‘spirit drink’ in case the mixture does not correspond 
to any spirit drink category.  
In that case, according to Article 13(3) , second subparagraph,  the list of 
alcoholic ingredients of a mixture is to be accompanied by at least one of the 
following terms: ‘mixture’, ‘mixed’ or ‘mixed spirit drink’.  
The selected term may precede or follow the list of alcoholic ingredients or be 
placed on another line with respect to it, as long as it appears in the same 
visual field as the list itself and the le gal name of the mixture.  
Moreover, both the list of alcoholic ingredients and the accompanying term 
shall appear in uniform characters of the same font and colour and in a font Mixtures  
52 size which half the font size used for the legal name or less (Article 13(3) , 
second subparagraph ). 
Finally, the label shall display at least once the percentage proportion of the 
volume of pure alcohol represented by each alcoholic ingredient in descending 
order of quantity used in the mixture (Article 13(3) , third subparagraph ). 
 NB: For the purpose of the labelling provisions on mixtures under the 
SDR, alcoholic ingredients  are either spirit drinks (as such), EAAO or 
distillates of agricultural origin, as indicated in Article 3, point 9 , of 
the SDR. On the other hand, in a list of  ingredients as regulated by  
Articles 18 to 22 of the FIC Regulation , the single ingredients of a 
spirit drink need to be broken down (i.e. the ingredients of an Orange 
Liqueur, which is a spirit drink as such, would have to be identified in 
an ingredients  list according to the FIC as e.g. EAAO, sugar and 
orange flavouring) . 
#42 - Example  of permitted labelling of mixtures  not belongin g to a category of spirit drink:  
Mixed Spirit Drink  
Scotch Whisky (60%), Grain Spirit (30%), Ethyl Alcohol  from barley  (10%)  
 
Spirit Drink  
Mixture of Kirsch Veneto (50%), Williams trentino (35%), Apple distillate (15%)  
 
Mixed Rum (60%) and Brandy (40%)  
Spirit Drink  
 
 
4.2.2.  Mixtures corresponding to a spirit drink category  
Article 13(4) provides the specific conditions of use and labelling for mixtures 
corresponding to one or more spirit drink categories . 
This is typically the case of liqueurs belonging to spirit drink category 33. In 
that case, the legal name of the mixture  will be one of the legal names 
provided for in the relevant category (e.g. ‘liqueur’, ‘cream’).  
Also in case of mixtures corresponding to one or more categories, the spirit 
drink names (categories or GIs) used in the production of the mixture may 
appear:  
‘a) exclusively  in a list of all the alcoholic ingredients contained in the 
mixture, which shall appear  in uniform characters of the same font and 
colour and in a font size which is no larger than half the font size used for 
the legal name ; and  
b) in the same visual field as the legal name of the mixture at least once .’  
Moreover, the label shall display at least once the percentage proportion of the 
volume of pure alcohol represented by each alcoholic ingredient in descending 
order of quantity used  in the mixture (Article 13(4) , third subparagraph ). Mixtures  
53 In conclusion, the differences between mixtures not belonging to a spirit drink 
category (a) and mixtures belonging to a spirit drink category (b) are limited to 
the following:  
1) the legal name of (a) is g enerically ‘spirit drink’ while for (b) it is one of 
the legal names allowed by the spirit drink category or categories to which 
the mixture belongs;  
2) in (b) the list of alcoholic ingredients does not need to be accompanied by 
the term defining a mixture (‘ mixture’, ‘mixed’ or ‘mixed spirit drink’).  
The remaining labelling conditions are the same in both cases.  
#44 - Examples  of permitted labelling of mixtures  corresponding to a spirit drink category : 
Liqueur  
Cognac (51%) & Orange liqueur (49%)  
 
Liqueur  
Coco Cream (60%) & Rhum de la Martinique  (40%)  
  
4.3. Checks  
Checks on the description, presentation and labelling of mixtures  address the 
compliance with following conditions:  
Production:  
1) the final product is a spirit drink in compliance at least with the definition 
of Article 2 of the SDR (or with the requirements laid down in Annex I for 
the spirit drink category they belong to);  
2) only distilled alcoholic components (spirit drinks, distill ates of agricultural 
origin and ethyl alcohol of agricultural origin or a combination thereof) 
have been used, while other foodstuffs may only be added as ingredients to 
liqueurs corresponding to spirit drink category 33 of Annex I;  
3) the spirit drink(s) ref erred to in the list of alcoholic ingredients comply /ies 
with all requirements laid down for its/their production in the relevant spirit 
drink category of Annex I or GI technical file/product specification, 
including its/their minimum alcoholic strength.  
Labelling:  
4) the legal name is ‘spirit drink’ for mixtures not corresponding to a spirit 
drink category laid down in Annex I or one of the legal names provided for 
under the spirit drink category which the mixture belong to;  
5) other spirit drink names (categori es or GIs) appear exclusively in a list of 
alcoholic ingredients, accompanied by a term indicating that it is a mixture 
(if the mixture does not belong to a spirit drink category);  
6) the list of alcoholic ingredients and the accompanying term are to appear i n 
the same visual field as the legal name of the mixture and are written in 
uniform characters of the same font and colour and in a font size which is 
no larger than half the font size used for the legal name;  Mixtures  
54 7) the label displays at least once the percentag e proportion of the volume of 
pure alcohol represented by each alcoholic ingredient in descending order 
of quantity used in the mixture.   Blends  
55 5. BLENDS  
Article 3, points  (11) and  (12) Definition s 
Article 13(3a)  Conditions for use and labelling provisions  
5.1. What are blends  
According to Article 3 , point (12), ‘ 'blend’  means a spirit drink that has 
undergone blending’  whereas according to Article 3, point (11), ‘'to blend’ 
means to combine two or more spirit drinks of the same category that are 
distinguishable only by minor differences in composition due to one or more of 
the following factors:  
(a) the method of production;  
(b) the stills employed;  
(c) the period of maturation or ag eing;  
(d) the geographical area of production;  
the spirit drink so produced belongs to the same category of spirit drinks as 
the original spirit drinks before blending .’ 
Blends are spirit drinks resulting from the combination of different 
spirit drinks bel onging to the same spirit drink category . Blends do 
therefore belong themselves to that same spirit drink category.  
In most cases, different spirit drinks of the same category are combined to 
reach certain desired organoleptic properties or to guarantee u niform 
characteristics of a spirit drink t hroughout the production years.  
For instance in the Scotch Whisky Industry, master blenders c hoose specific 
single malts and single grain whiskies to make particular brands of blended 
Scotch Whisky.  
This is a commo n production practice, which does not raise any concerns as to 
the possibility to mislead consumers.  
However, the definition of blends also covers the combination of spirit drinks 
belonging to the same category  but at the same time to different geographica l 
indications (e.g. Cognac and Armagnac) or of spirit drinks belonging to the 
same category, one of which is a geographical indication but not the other (e.g. 
Kirsch and Kirsch d’Alsace).  
In order to protect the reputation of geographical indications, the legislator has 
extended to blends made of spirit drinks belonging to different geographical 
indications or belonging only in part to geographical indications analogue  
conditions of use and labelling rules already provided for mixtures (Article 
13(3a)37). 
                                                 
37  Introduced by Commission Delegated Regulation (EU) 2021/1096 of 21 April 2021 amending 
Regulation (EU) 2019/787 of the European Parliamen t and of the Council as regards labelling 
rules for blends (OJ L 238, 6.7.2021, p. 1) . Blends  
56 5.2. Conditions of use and labelling provisions  
Article 13(3a) provides for the general condition of use and labelling for 
blends . 
The legal name  will be one of the legal names provided for the spirit drink 
category to which the blend belongs.  
Obviously, in app lication of Article 10(5) , point (a), the legal name may be 
supplemented or replaced by a geographical indication for spirit drink, where 
all the requirements laid down in its technical file/product specification are 
complied with.  
In the case of blends of spirit drinks belonging to different geographical 
indications or belonging only in part to geographical indications , following 
labelling rules apply:  
a) according to  Article 13(3a) , second subparagraph, point (a), letter (i),  the 
names corresponding to the blended spirits drinks may appear ‘ exclusively 
in a list of all the alcoholic ingredients contained in the blend  which shall 
appear in uniform characters of the same font and colour and in a font size 
which is no larger than half the font size used for the legal name ’; 
b) according to Article 13(3a), second subparagraph, point (a), letter (ii), those 
names are to appear  ‘in the same visual field as the legal name of the blend 
at least once’ ; 
c) according to Article 13(3a) , second subparagraph, point (b),  the list of 
alcoholic ingredients shall be accompanied by at least one of the following 
terms: ‘blend’, ‘blending’, or ‘blended’ ; The selected term may precede or 
follow the list of alcoholic ingredients or be placed on another line with 
respect to it, as long as it appears in the same visual field as the list itself 
and the lega l name of the blend;  
d) according to Article 13(3a), second subparagraph, point (c) , the label shall 
display at least once the percentage proportion of the volume of pure 
alcohol represented b y each alcoholic ingredient in descending order of 
quantity used in the blend.  
 NB: The above provisions aim in particular at protecting the reputation of 
certain geographical indications. Therefore, they do not apply to 
blends of spirit drinks belonging to the same GI or none of which 
belongs to a GI because blending is a common production process 
used for manufacturing certain spirit drinks and the specification of 
the quantity of each different spirit drink in a blend is not relevant.  
#43 - Examples  of permitted labelling of blends  of spirit drinks belonging to different geographical 
indications or belonging only in p art to geographical indications:  
Blended Wine Spirit  
Cognac (51%) & Armagnac (49%)  
 
Whisky  
BLEND  
Spanish Whisky (75%) + Irish Whiskey (20%) + Canadian Whisky (5%)  
 Blends  
57 5.3. Checks  
Checks on the description, presentation and labelling of blends  address the 
compliance with following conditions:  
Production:  
1) Only spirit drinks of the same category may be combined in a blend: these 
are distinguishable only by minor differences in composition due to the 
factors listed in Article 3 , point (11), of the SDR (see § 5.1 above);  
2) the final product belongs to the same spirit drink category as the spirit 
drinks that are combined in the blend;  
Labelling of blends:  
3) the legal name is one of the legal names provided for the spirit drink 
category to which the blend belongs;  
4) the legal name may be supplemented or replaced by a geographical 
indication for spirit drinks when all relevant conditions are met; 
5) in the case of blends of spirit drinks belonging to different geographical 
indications or belonging only in part to geographical indications:  
a. the names of the spirit drink composing the blend  (categories or GIs) 
appear exclusively in a list of alcohol ic ingredients;  
b. the list of alcoholic ingredients appears in uniform characters of the 
same font and colour and in a font size which is no larger than half the 
font size used for the legal name;  
c. the list of alcoholic ingredients appears at least once in th e same visual 
field as the legal name of the blend;  
d. the list of alcoholic ingredients is  accompanied by a term indicating 
that it is a blend;  
e. the label displays at least once the percentage proportion of the volume 
of pure alcohol represented by each alcoholic ingredient in descending 
order of quantity used in the blend.   Overview Tables  
58  
6. OVERVIEW TABLES  
6.1. Compound Terms (CT)  
DEFINITION :  
Article 3, point (2) Combination (resulting in an alcoholic beverage ) 
of one spirit drink name (category or GI) with : 
1) the name or derived adjectives of one or more 
foodstuffs (other than an alcoholic beverage and 
other than foodstuffs used for the production of 
that spirit drink), and/ or 
2) the term ‘ liqueur ’ or ‘ cream ’. 
CONDITIONS 
FOR USE :  
Article 11  a) All the alcohol originates from the spirit drink  
referred to in the CT, except for alcohol present 
in flavourings, colours and other authorised 
ingredients  
b) No dilution only with water reduc ing the 
alcoholic strength below the required ABV  
LABELLING 
REQUIREMENTS :  
Article  11  No use of terms ‘alcohol’, ‘spirit’, ‘drink’, ‘spirit 
drink’, ‘water’  in the CT  
 (Legal) name:  
- ‘spirit drink’ for spirit drinks not complying 
with the requirements of any category , 
- compound terms combining the name of the 
spirit drink with the term ‘liqueur’ or ‘cream’ 
for spirit drink complying with the relevant 
requirements of category 33 of Annex I, or  
- the name of the alcoholic beverage  according to 
the FIC Regulation , if it is not a spirit drink  
 Display CT in a font size no larger than the font  
size used for the (legal) name  
 Display CT in uniform characters (same font, 
size, colour)  
 CT not interrupted by any textual or pictorial 
element not forming part of those  
 In case of combination resulting in a spirit drink, 
its legal name must always accompany the CT: 
both to appear in the same visual field  
  Overview Tables  
59 6.2. Allusions  
DEFINITION :  
Article 3, point (3) Direct or indirect reference to one or more spirit 
drinks (categories or GIs)  in the (description,) 
presentation and labelling of: 
1) foodstuffs other  than alcoholic beverages  
2) alcoholic beverages other than spirit drinks  
3) liqueurs (spirit drinks of categories 33 -40) 
4) spirit drinks other than liqueurs (in limited, 
specific cases  not qualify ing as CT or mixtures ) 
CONDITIONS 
FOR USE :  
Article 12  a) All the (added) alcohol originates from the spirit 
drink  (except for all usions on spirit drinks’ casks)  
b) For spirit drink GIs only : the product covered 
by the GI name should be used in sufficient 
quantity  (% to be indicated on the label)  to confer 
an essent ial characteristic to the foodstuff 
concerned (taste attributable primarily to the 
presence of the GI  or – where impossible to prove 
– appropriate documentary evidence ) 
c) For spirit drink GIs only : no other ‘comparable’ 
ingredient has been used  
LABELLING 
REQUIREMENTS : 
Article 12   For 1 ) only : FIC rules apply  
 For 2) only: name = the name of the alcoholic 
beverage according to the FIC 
 For 3) only: legal name = ‘liqueur’ the legal name 
of the other liqueur category whose requirements 
it complies with  + no use of the  term «  cream  » in 
English  
 For 4) only: legal name = any of the names 
permitted by a category for spirit drinks whose 
requirements are complied with  (legal name ‘spirit 
drink’ only allowed in case of allusions to spirit 
drink casks)  
 For 2) to 4):  Allusion not on the same line as 
(legal) name of the alcoholic beverage + in a font 
size no larger than half the font size used for the 
(legal) name and (possible) CT (except for 
allusions to spirit drink casks, which may use the 
same font size as th e legal name  and possible CT ) 
 For 3) + 4): Allusion always accompanied by the 
legal name of the spirit drink : both to appear in 
the same visual field  
 For 2 )+ 3): List of alcoholic ingredients indicating 
% of alcohol in descending order  at least once  
  Overview Tables  
60 6.3. Mixtures  
DEFINITION :  
Article 3, points (9) 
and (10) Combinations of different distilled alcoholic 
ingredients , i.e. spirit drinks (categories or GIs), 
ethyl alcohol of agricultural origin and/or distillates 
of agricultural origin resulting in : 
1) a spirit  drink  not belonging to a category; or  
2) a spirit drink belonging to a category  (e.g. 
liqueur)  
LABELLING 
REQUIREMENTS :  
Article 13(3)  and (4)  For 1 only: l egal name  = ’spirit drink’ 
 For 2 only: legal name = category name  
 Names of s pirit drinks (categories or GIs) 
mentioned only in a list of alcoholic ingredients in 
the same visual field as legal name  
 The list of alcoholic ingredients indicates  in 
descending order the % of alcohol represented by 
each in the mixture  at least once  
 For 1 only: i ndicate one of the terms ‘mixture’, 
‘mixed’ or ‘mixed spirit drink’  where the list of 
alcoholic ingredients is provided  
6.4. Blends   
DEFINITION :  
Article 3, points (11) 
and (12) Combinations of different spirit drinks belonging 
to the same category  with slight differences in:  
1) production method;  
2) stills employed;  
3) maturation or ageing period ; and/or  
4) geographical area of production  
LABELLING 
REQUIREMENTS :  
Article 13(3a)   Legal name = category name  (which may be 
supplemented or replaced by the name of a GI)  
ONLY for  blends of different GIs or GIs+non GIs : 
 Names of other s pirit drinks (categories or GIs) 
only mentioned in a list of alcoholic ingredients in 
the same visual field as legal name at least once  
 Indicate one of the terms ‘blend’, ‘blending’ or 
‘blended’  where the list of alcoholic ingredients is 
provided  
 The list of alcoholic ingredients indicates  in 
descending order the % of alcohol represented by 
each in the blend at least once