Labelling and selling wine in Republika Srpska: label and sales to guests

This article is for registered wine producers (companies and entrepreneurs) in East Herzegovina who bottle wine and offer it to guests, restaurants and shops, and for hospitality venues that serve wine. It explains what the label must show and the conditions for selling and serving wine.

In short

• Wine is, as a rule, placed on the market only in original packaging, and every original-packed wine needs a decision of the RS Ministry of Agriculture, Forestry and Water Management (Ministarstvo poljoprivrede, šumarstva i vodoprivrede) before sale.
• Only a company or entrepreneur entered in the Wine Register may produce and sell wine. Wine made for personal use may not be displayed or sold at a market, in a hospitality or retail outlet or at a fair (fine 500 to 1,500 KM).
• The BiH state Law on the Organisation of the Wine Market (Sl. glasnik BiH 63/23) has applied since September 2024 and lists the mandatory label elements. The RS Law on Wine (80/15) has not been amended to match it, so both are in force.
• A producer may offer and serve its own wines in hospitality venues and in tourist households.

Who it applies to

Wine producers entered in the Wine Register (companies or entrepreneurs), importers, and hospitality venues and rural households that serve or sell wine. A household or farm acting as a private person cannot lawfully sell wine it makes itself: anyone who makes wine for own needs, or is not a wine producer within the meaning of the law, and displays or sells that wine at a market, in a hospitality or retail outlet or at a fair is fined 500 to 1,500 KM (RS Law on Wine, art. 50(2) and art. 58). Guesthouses and restaurants that only serve wine bought in original packaging, with a market decision, do not produce wine and need no Wine Register entry for that.

Mandatory label elements

Under article 41 of the state law (BiH 63/23), the label of wine placed on the BiH market must show:

• the product category (for example "wine"), except where the label carries a protected designation of origin or geographical indication name;
• for wines with a protected designation: the words "protected designation of origin" or "protected geographical indication" and the name;
• actual alcoholic strength by volume;
• indication of provenance;
• bottler (for sparkling wines, the producer or seller name);
• the importer, for imported wines;
• sugar content, for sparkling wines;
• nutrition declaration and ingredients list under the special food information rules (these may be provided electronically, with an indication on the pack, under the conditions in the law).

This is not the full list. The general food labelling rules also apply (art. 40), for example quantity and allergens. If the ingredients list is given electronically, the pack must carry the word "contains" followed by the allergens (art. 41(5)), and with an electronic nutrition declaration the energy value must be on the pack (art. 41(4)). Article 41 also has special rules for dealcoholised wines.

Wording must be in one or more languages in official use in BiH (art. 43). Vintage and grape variety are optional (art. 42). Quality and origin terms may be used only as the law allows and must not mislead the consumer (RS Law on Wine, art. 30(4)).

What to do

1. Check that you are entered in the Wine Register kept by the RS Ministry of Agriculture, Forestry and Water Management. If not, apply to the Ministry for a commission to establish that you meet the conditions (premises, equipment, equipment and an expert person). The application includes the court or entrepreneur registration decision, proof of the expert person and proof of the administrative fee paid. The minister then issues a decision on meeting the conditions and entry in the register (RS Law on Wine, arts. 11 and 13). Without registration there is no lawful sale.
2. Before filling, the wine is tested (physical, chemical and sensory properties, art. 27). Sensory assessment by the Commission is mandatory for wine with geographical origin (art. 29).
3. Bottle and label the wine yourself, with your own label (art. 30). Match the label to the list above.
4. Apply to the Ministry for the decision allowing the wine onto the market, with an analytical report on quality (art. 42(8)). For wine with geographical origin the application also needs an expert opinion of an authorised institution on grape and wine production and the decision on meeting the conditions to use the designation (art. 42(8)(2)). After the decision the wine may not be altered.
5. Young wine may be sold until 31 December of the harvest year (art. 45).

Selling to guests

• A producer may offer and serve its own wines in hospitality venues, in households engaged in tourism, in shops and at wine exhibitions (art. 42(4)).
• In a hospitality venue wine is kept in original packaging. Exceptionally, table wine and table or quality wine with controlled geographical origin may be kept and sold as open goods from containers of up to 60 litres. Serving by the glass from originally sealed containers of up to 5 litres is not open sale (art. 42(5) and (6)).
• A producer may offer bulk wine within its own winery and at wine events if the quantity was reported to the Ministry (art. 43(3)). Displaying and selling bulk wine at a market, in a hospitality or retail outlet and at a fair is banned for the producer (art. 50(1)). In practice, a producer does not take bulk wine to a restaurant or market to sell it.
• A hospitality venue may hold open goods only within art. 42(5). The state law is stricter: open sale requires exact purchase and sales records, and wines with a protected designation of origin or geographical indication, varietal wines and vintage wines may not be sold as open goods in hospitality (art. 50). In retail, wine is sold only in originally sealed bottles, and open goods may be sold only by registered producers in their own production premises or specialised shop (art. 49). The safest course is to sell only in original bottles.

Fines

Fines under the RS Law on Wine:

• Art. 55, for selling wine without a decision, altering wine after the decision, and packing and labelling contrary to the quality rules: company 5,000 to 15,000 KM, entrepreneur 3,000 to 9,000 KM, responsible person in a company 2,000 to 6,000 KM.
• Art. 56, for holding or selling wine contrary to art. 42, and for wine not in original packaging or not declared properly (art. 43), in shops and hospitality venues: company 3,000 to 9,000 KM, entrepreneur 2,000 to 6,000 KM, responsible person 1,000 to 3,000 KM.
• Under art. 57 the items involved can also be seized.

Note on current rules

The RS Law on Wine (80/15) is listed as active in the register of regulations and there is no new entity wine law. The state law gave the entities six months to harmonise (art. 74). Most implementing regulations are adopted by the BiH Council of Ministers (art. 73), but the premises requirements and manner of selling wine as open goods, and the way records are kept in hospitality, are set by the competent institutions of the entities (here Republika Srpska) and of Brčko District (art. 49(4), art. 50(5)). Check details with the Ministry and the inspectorate before printing labels.

Where to go

• RS Ministry of Agriculture, Forestry and Water Management: Wine Register and market decision (vladars.rs).
• Republička uprava za inspekcijske poslove (Republic Administration for Inspection Affairs): agricultural inspectors and food inspectors, and agricultural inspectors in municipal administrations (Trebinje, Bileća and others), art. 51 of the Law on Wine.

Laws and sources

• Zakon o vinu (Službeni glasnik Republike Srpske br. 80/15), arts. 11, 13, 27, 29, 30, 42, 43, 45, 50, 55, 56, 57, 58
• Zakon o organizaciji tržišta vina u Bosni i Hercegovini (Službeni glasnik BiH br. 63/23), arts. 40, 41, 42, 43, 49, 50, 73, 74, 79