ANALYSIS OF U.S. WINE AND SPIRITS FOR EXPORT TO JAPAN
Proprietors of Distilled Spirits Plants, Bonded Wine Cellars and Breweries.
Purpose: The purpose of this industry circular is to notify the public of the
details concerning the recent decision of the Japanese Ministry of Finance to
accept analytical data prepared by ATF-certified laboratories in order expedite
entry of U.S. wine and spirits into the Japanese market.
Background: Several years ago, the Japanese Ministry of Health and Welfare
indicated its willingness to accept analytical data prepared by ATF-certified
laboratories in an effort to facilitate the entry of U.S. wine and spirits into
Japan.
The concerns of the Ministry of Health and Welfare were and continue to be
focused on:
- for spirits (e.g., liqueurs), the name of any coloring agents used; and,
- for grape and other fruit wine, the sulfur dioxide and sorbic acid content.
The Japanese Ministry of Finance has recently indicated that it, too, is now
prepared to accept analytical data determined by ATF-certified laboratories.
While the data sought by the Ministry of Health and Welfare is health-related,
the concerns of the Ministry of Finance focus on analyses needed for tariff and tax
classification of wines and spirits. (Like the Ministry of Health and Welfare, the
Ministry of Finance does not require analysis for beer.)
Analytical Data: There are three analyses of interest to the Ministry of Finance,
but not all three are needed for every product. The analyses are:
1 - the determination of alcohol content in terms of percent by volume at
20°C. Any means may be used to determine alcohol content;
2 - the determination, by gas pressure measuring device, of the pressure, due to
carbon dioxide gas, in the headspace as determined by a gas pressure measuring
instrument when the product is kept at a temperature of 20°C in closed
containers;
3 - the determination of extract content in grams of the evaporation residue per
100 cm³ of product at a temperature of 15°C.
The following table identifies, in terms of product name and appropriate
Japanese tariff category, the products to which one or more of the above analyses
apply. It also specifies which analyses are needed (i.e., 1 - alcohol,
2 - pressure, 3 - extract):
JAPANESE TARIFF CATEGORY
|
ANALYSES |
SAKE (22.06) |
1 AND (2) |
SAKE COMPOUND, SHOCHU, MIRIN (22.08) |
1 AND (2) |
BEER (22.03) |
UNNECESSARY |
WINES (22.04, 22.05, 22.06) |
1 AND 2 |
WHISKIES (22.08) |
1 AND (2) |
SPIRITS, LIQUEURS (22.08) |
1, (2) AND 3 |
OTHER LIQUEURS (e.g., 2206.00.222, 2208.90.240) |
1 AND 2 |
Where the tariff category of an alcoholic beverage cannot be clearly identified
for liquor tax purposes, exporters may be required to submit data about raw
materials and manufacturing process.
Where 2 is shown in parentheses [i.e., (2)], this indicates that some products
falling under the referenced tariff category may require gas pressure analysis
while others may not. Although the Ministry of Finance does not specifically
identify the products requiring this analysis, it is advisable to determine gas
pressure whenever the product exhibits effervescent qualities upon visual
examination.
The presentation of the analytical data referenced herein is not required as a
condition of entry. Occasionally, Customs inspection is limited to label
examination and does not involve sampling and analysis; however, if it is decided
that analysis is needed and if the analytical data is not included as part of the
shipping documents, entry may be delayed pending completion of analysis by Japanese
Customs laboratories.
There is no specific form or format required for the presentation of these
analyses nor must analyses be signed; however, the name and address of the
ATF-certified laboratory which performed the analyses should be clearly identified.
Additional Information and Inquiries: A listing of the laboratories certified by
ATF for the analysis of wine and more specific information on Japanese tariff and
tax classification and rates is available. Inquiries in this regard and questions
concerning this circular should refer to its number and be addressed to:
Chief, Alcohol Import-Export Branch
Bureau of Alcohol, Tobacco and Firearms
1200 Pennsylvania Avenue, NW
Washington, DC 20226
Director
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