Clarifications on the technical regulations for alcoholic beverages in Russia

At the request of the Ministry of Industry and Trade, the Ministry of Finance of the Russian Federation prepared an official letter about the application of the technical regulations of the Eurasian Economic Union "On the safety of alcoholic beverages (TR EAEU 047/2018)", which was signed and published on October 7, 2020. This letter was a response of the Department of Customs Policy and Alcohol Market Regulation to the appeal of the Ministry regarding the application of the "alcohol" regulation.

What if there is a conflict between national and EEU regulations?

The document states that, in accordance with the Treaty on the Eurasian Economic Union, standards (international and interstate, and in their absence - national standards of the EAEU countries) may be applied voluntarily to confirm compliance with the EU technical regulations and to assess the compliance of products with their requirements.

As a consequence of this provision, the requirements of the standards should not contradict the provisions of the regulation. If such contradictions exist, the standard must be amended in such a way that the law is harmonized in this respect.

Regulation of additives in alcoholic beverages

The document discusses the possibility of using food additives in alcoholic beverages. It was explained in detail that Annex 4 (Table 8) to the technical regulation TR EAEU 047/2018 specifies the requirements for the maximum level of certain food additives in beer.

In addition, it was noted that according to the technical regulation TR CU 029/2012 "Requirements for the safety of food additives, flavorings and technological aids", other food additives with technological functions are used.

This means that if the Alcohol Regulation does not contain direct prohibitions or exceptions regarding the use of food additives, then in the case of their use in the production of alcoholic products, the requirements approved in the technical regulation TR CU 029/2012 are imposed.

Allowed units of sugar concentration in alcohol

Another issue requiring clarification was the possibility of indicating sugar concentration in the units of "g / 100 ml" on the label of alcoholic products. The Ministry of Finance informed that the indicator can be indicated only in such formats as:

  • g / dm3;
  • g / l;
  • g / 100 cm3.