The European Union has set maximum residue levels (MRLs) for pesticides in and on food products. Products containing more pesticide residue than allowed will be withdrawn from the Polish market. The European Commission currently includes 647 pesticide residues with limits varying from one pesticide residue to the other and one product to the other. For substances that are not yet included in the European regulation, the default MRL of 0.01mg/Kg applies.

The most often detected residues in wines include fenhexamid, iprovalicarb and boscalid. Conventionally grown wine grapes are one of the crops extensively treated with pesticides. Studies have found pesticide residues in more than 90% of wines examined. Hence, Polish importers request a detailed test for the presence of pesticide residues. Note that buyers in several Member States, including Poland, apply MRLs that are stricter than those established in the European Union legislation. The MRLs applied and their relative strictness very according to the buyer. Always consult your buyer to determine the specific adopted MRLs.

According to FAO, contaminants are substances that have not been intentionally added to food, but which may be present as a result of the various stages of its production, packaging, transport or holding. There are threshold limits set for several contaminants, in order the avoid negative impact on the quality of food and risks to human health. Therefore, it is crucial for the exporter to know of and comply with the maximum levels allowed by European legislation. The European Commission Regulation sets maximum levels of certain contaminants in food products. The EU frequently releases updates to the regulations set on 19 December 2006. The latest update on 14 October 2020 specifies the maximum levels in the table below. For wine, there is a risk of contamination of Ochratoxin A (OTA) by certain mold species and of lead mainly by brass tubes and faucets. The maximum allowed level for Ochratoxin A is 2.0 μg/kg (a mycotoxin). For lead there is a threshold limit of 0.20 mg/kg.

Wine marketed in Poland must meet the requirements of the European Union’s food safety schemes and food hygiene legislations. The starting point is that all food placed on the market must be safe. To guarantee food safety and to allow appropriate action in cases of unsafe food, food products must be traceable ‘from-farm-to-fork’, risks of contamination must be limited by defining the Hazard Analysis and Critical Control Points principles (HACCP) and food products are subjected to official controls.

Bottled Wine • Glass bottles are the most common type of wine packaging. Glass bottles are usually colored to reduce the effect of UV light and typically contain 0.75 liter, but there is a growing trend in Poland toward sales of wine in one-liter bottles. In Poland, Bag-in-Box (BiB) packaging is hardly used for premium wine; it only had some success in the on-trade. • Screw caps are still associated with cheap alcoholic beverages (e.g. vodka) and therefore not preferred by most Polish wine consumers. Traditional corked bottles are most common, especially in the premium wine segment. • Bottles for sparkling wines need to be strong enough to withstand the pressure resulting from the high CO2 levels. Bulk Wine Packaging-related quality problems with bulk wine hampered development of bulk wine trade for a long time. Recent improvements in storage technology, handling facilities, and quality protocols have contributed to better-quality preservation. These developments have caused an explosive growth in the trade of bulk wines, especially among the international brands. Different types of packaging are available for the transport of bulk wine. The two most common are: • Flexi-tanks – disposable plastic bags intended for installation in a standard 20-ft shipping container. • ISO tanks – reusable steel tanks, which need to be cleaned between shipments. ISO tanks offer all the advantages of flexi-tanks, but are more polluting and expensive in transport due to higher weight. One advantage of an ISO tank is its reliability; they have a lower risk of defects compared to flexi-tanks. Defective seals or the use of permeable material can lead to oxidation, which will degrade the wine. This can result in negative taste alterations and a shorter shelf life. Food Contact Materials Toxic substances can be found in the glass and decoration of wine bottles. Wine producers also sometimes opt for different packaging options. Specific health control provisions apply to consumer packaging materials that come into contact with food (e.g. bottles, containers). For example, food contact materials made from recycled or other plastic and ceramic must be manufactured in a manner that prevents them from transferring constituents to food in quantities that could endanger human health, change the composition of the food in an unacceptable way or cause deterioration in the flavor and odor of foodstuffs. Commonly restricted substances include vinyl chloride monomer N-nitrosamines, N-nitrosatable BADGE, NOGE, BFDGE and heavy metals.

There are strict rules on which information should be shown on the label and how this information has to be presented. The European Union has set compulsory labelling particulars for wine. Wine packaging labels should include the following information: • The name of the Protected Denomination of Origin (PDO), Protected Geographical Indication (PGI), Wine of ‘producing country’, Produced in ‘producing country’, Product of ‘producing country’, • Actual Alcoholic Strength (AAS), • Nominal volume, • Lot number, • Sugar content (for sparkling wines), • Importer details, and • Allergenic ingredients. Mandatory information must appear in the same field of vision on the container in such a way that all the information (except the lot number, importer’s details and allergens) is readable without having to turn the container. It must be clearly distinguishable from surrounding text or graphics. Wine packaging labels may include the following additional information, which is left to the discretion of the manufacturer or the export destination country: • Trademarks, • Parties participating in the marketing process, • Name of viticulture holding (château, quinta, finca, tenuta, Weingut, manor, estate, etc.) • Varietal name (if the wine is produced from at least 75% of grapes of that varietal; two names mentioned if the wine comes entirely from those two varietals; more than two names accompanied by the percentage of composition), • Vintage or harvest year, • Type of wine (dry, medium dry, mellow or semi-sweet and sweet), • The ageing of wine, • Traditional terms of quality, • Medals and distinctions, • Other terms (such as history of wine or commercial firm, consumer advice, sensory condition, wine color, natural conditions or vine growing techniques, etc.) Only information from the compulsory and optional labelling particulars are allowed on wine packages. With the exception of allergen information, which must appear in Polish, the labeling requirements above may appear in one or more of the official languages of the EU. Furthermore, there are rules for the use of certain bottle shapes which may only be used for certain types of wine. Allergens Pre-packed products that contain allergens must be labelled in such a way that the presence of allergens is clearly visible to consumers. Under Regulation (EU) No 1169/2011, allergens must be highlighted in the list of ingredients. Requirements concerning allergen information also apply to foods that are not pre-packed, including those sold in restaurants and cafés. The information on allergenic ingredients in wine products should be mentioned in the language of the target market (i.e. Polish) and include the following information: • All wines containing over 10 milligrams of sulphite per liter must be labelled with the indication ‘Contains sulphites’. This information is crucial for individuals who are sensitive to sulphites and experience problems such as shortness of breath, coughing, and wheezing. To accommodate these consumers, wines with only a few mg or no sulphite could indicate that on the label. • If egg and milk derivatives are used, it must also be mentioned on the label.

Food hygiene (based on HACCP methodology) is a legislative requirement for producers and exporters of wine entering the Polish market. Although food safety certification is not obligatory under European legislation, it has become a must for almost all Polish food importers. Most established Polish importers will not work with you if you cannot provide some type of comprehensive food safety certification. Compliance with such additional standards can allow wine exporters to enter specific market segments or gain competitive advantages relative to their competitors. Certifications concerning general quality and food safety management systems from recognized and trustworthy sources demonstrate the supplier’s commitment to high and consistent quality and safety. As a general rule, quality management requirements become stricter at higher levels of processing and packaging. Many Polish buyers, especially large retailers and private label manufacturers, will ask for Global Food Safety Initiative (GFSI) recognized certification. For wine, the most popular certification programs recognized by GFSI are: • International Featured Standards (IFS): This standard corresponds to ISO 9001, but with a focus on food safety, HACCP, hygiene, the manufacturing process and business surroundings. The IFS is a quality and safety standard published by the union of German supermarket chains, HDE (Hauptverband des Deutschen Einzelhandels). • British Retail Consortium Global Standards (BRCGS): This private institution promotes private (BRC) standards, which contain rules on Good Manufacturing Practices (GMP) that extend beyond the HACCP plan (e.g. regarding organization and communication). • ISO 22000: This standard combines the HACCP plan with prerequisite programs (PRPs). It specifies requirements for a food safety management system along the food chain, up to the point of final consumption. • Food Safety System Certification (FSSC 22000): This standard is based on the existing international standards ISO 22000 and ISO/TS 22002-1. • Safe Quality Food Certification (SQF): A comprehensive HACCP-based food safety and quality management system. This list is not exhaustive and food certification systems are constantly developing. Although the various food safety certification systems are based on similar principles, some buyers prefer one specific standard over the other. Food safety certification is only a basis to start exporting to Poland. Serious buyers will usually visit or audit your production facilities before buying.

Polish buyers pay more and more attention to their corporate responsibilities regarding the social and environmental impact of their business. This is not just driven by governmental guidelines but also by the changing market. Millennials (people born between 1982–2000) are more concerned about the origin and the way a wine has been made than ever before. This also affects you as a supplier. Common requirements are the signing of a suppliers’ code of conduct in which you declare that you and your suppliers do business in a responsible way. Several larger retailers participate in initiatives such as the Ethical Trading Initiative (ETI) or the Business Social Compliance Initiative (BSCI). These initiatives focus on improving social conditions in their members’ supply chains. This implies that you, as a supplier, are also required to act in compliance with their principles.

The requirements of many Polish buyers concerning sulphites are stricter than EU legislative requirements. Buyers generally prefer low sulphite levels (e.g. < 100 mg/l for white wine). However, sulphite is a preservative and lower sulphite levels may lead to off-tastes and reduced shelf life. Use of fertilizers can improve soil quality. However, wineries should minimize the use of chemical fertilizers, as Polish consumers are concerned about effects of agriculture on the environment and the use of chemicals in particular. Particularly big buyers in Poland indicate that producers of wine can improve their chances of successful market entry by showing professionalism. Communication and sampling are areas in which producers in developing countries in particular can improve.

Wine can be certified as organic when its grapes are grown in accordance with organic farming principles. This implies the use of grapes that are cultivated without the use of any artificial chemical fungicides, pesticides, herbicides or fertilizers. Organic viticulture (the production of organic wine) includes protection of the natural balance of the vineyard and its surrounding environment during the production process. At the winemaking level, organic techniques are used. This means little to no manipulation of wines by reverse osmosis and excessive filtration and no use of flavor additives. Wine can only carry the organic label when it meets the criteria set by certification agencies. Such criteria differ across agencies and countries worldwide. In order to be accepted by Poland as an organic product, a certification that complies with EU standards concerning organic wine is needed and the grapes and the wine production facilities must be audited by an accredited certifier. Only then may the producer put the European organic logo on their products, as well as the logo of the standard holder. Biodynamic Wine Biodynamic wine production shares many principles with organic wine production. In biodynamic viticulture, the farm is seen as a cohesive interconnected living system. It excludes chemicals from the production system, but also uses some spiritual practices. Biodynamic producers believe that these spiritual practices help to improve the vineyard’s health. Producers can get certified against standards for biodynamic wine production as laid down by Demeter International. Natural Wine A legal definition of natural wine does not exist. Generally, natural wine producers believe that minimal chemical and technological intervention during wine production is better for the vineyard and wines. They take organic or biodynamic wine production one step further by applying even stricter rules for the use of additives and the removal of anything from the wine. Natural wines improve by ageing due to the high tannins in the wine.

Fair trade wine typically refers to wine that has been certified by Fairtrade International or Fair for Life. The ‘fair trade’ concept promotes fair pricing and improved social conditions for producers and their communities. Wine producers can have their products labelled as Fairtrade by going through a certification process that ensures compliance with specific economic, social, and environmental standards. Fairtrade-certified products will not be sold at a premium price. Wines still need to be very competitive on price points, but it allows exporters from developing countries to be active in their own niche segment.