Comments from EU relating to Draft Technical regulation on alcoholic products safety.

Labeling requirements.

The EU has the following concerns regarding labeling provisions: The EU is of the opinion that the indication of the mass concentration of sugars for wines (Article 6.16 sub 6) should not be required since there is no such requirement at international level. The EU considers that the indication of the month and the year of tirage for collection sparkling wines and high quality collection sparkling wines (Article 6.16 sub 9) should not be required as it brings no added value to the consumer and could be misleading. Instead, the vintage year should be indicated. The indication of the date of bottling is irrelevant for some products such as sparkling wines. Therefore the EU would like to suggest to Russia that only the production date is mentioned in order to avoid misleading consumers (Article 6.16 sub 13).The indication of the storage conditions is unnecessary for products containing more than 10% by volume of alcohol (Article 6.16 sub 14).With regard to the size of the health warning (which must cover 20% of the label) the EU would like to receive clarification as regards the reasons for setting out this requirement and, in particular whether more feasible size requirements have beenconsidered.7 In this respect, the EU would like to recall Article 2.2 of the TBT Agreement, which states that: "Members shall ensure that technical regulations are not prepared, adopted or applied with a view to or with the effect of creating unnecessary obstacles to international trade". The EU would like to receive clarification of what is meant by "the indication of the document in compliance with which the alcoholic beverage is produced" as this is unclear. In any case, this requirement does not seem to have any equivalent in the international practice (Article 6.16 sub 17).The requirement that the information on the label should be provided in Russian and in the languages of the other members of the Customs Union is excessive and unjustified (Article 6.21).

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Comments from EU relating to Draft Technical regulation on safety of chemicals.

Labeling requirements.

It is not clear to the EU what is meant in Article 7, paragraph 1 by "the name of the document in accordance with which chemical products have been manufactured (when available)" and why this would have to be indicated on the label. Could the Russian authorities provide some examples? It is not clear that the labelling requirements concur fully with the GHS rules, in particular the various elements such as pictograms, signal word, hazard and precautionary
statements. Are these all contained in GOST standard 31340 which is referred to in paragraph 5 of Article 7 and in Article 8?

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