Wine ingredient labeling: Has the industry shot itself in the foot?

Nate_Simon · August 8, 2020, 3:07pm

“Among millennials, health and convenience are driving purchasing decisions, and wine is losing market share.“

Adam_G · August 8, 2020, 10:21pm

I would like all wines to state the pH, TA, abv, and any “ingredients” that are beyond grapes and yeast. The last one is least important to me if I’m looking at a wine bottle and deciding whether it’s likely for me to enjoy its contents.

Sean_S_y_d_n_e_y · August 8, 2020, 10:43pm

I fundamentally agree that ingredients should be listed on a wine label or at least mandated to be publicly available from the manufacturer, but it gets into interesting questions. Is chaptalization an “ingredient”? If it’s filtered through egg whites or casein, is that necessary to put on the label? Does cultured yeast mandate a mention? If a uses copper sulfate on the grapes, does that go on? All relevant, all matters of opinion.

DougS · August 9, 2020, 1:29pm

Millennials are drinking plenty of spirits and beers that don’t have ingredient labels, and I don’t think they are a key consumer segment for the newfangled “clean” wines (marketed as such). The article seems to be more about what the author wants than what the facts suggest.

DougS · August 9, 2020, 1:41pm

Yes.

Those are fining agents, not filtering. If the finished wine has lab tests showing there’s none left in the wine, then it doesn’t need to be labelled. If there’s some in there, then it does.

I think it would depend on whether or not there’s any in the finished wine, but I am not sure on this one. I do think there’s an existing food labeling regulation that would say.

Again, lab tests decide.

I don’t think they are matters of opinion. The food industry already has a set of rules about ingredient labeling. The wine industry likes to pretend those rules don’t exist so they can create confusing arguments like this and avoid ingredient labeling. I’m not sure that all of my responses are correct in terms of those regulations, but the point is that this isn’t about opinion. Some mass produced non-alcoholic beverages also have relatively complicated methods of production and are sometimes treated with things that no longer exist in the finished product. Wine is not special because of these characteristics. I think all food and beverages, ESPECIALLY alcoholic drinks (the only thing I know of that’s exempt, and potentially one of the most dangerous thing legally sold to us as consumables) should have ingredient labels. I don’t think it would cause Millennials to drink more wine.

Paul_Miller · August 9, 2020, 1:51pm

What about Mega Purple?

Marc_Hauser · August 9, 2020, 2:12pm

Has the industry lost its mind?!?!?!?!

The article is a bit more balanced. I appreciate she calls out the bullshittiness of “clean wine” marketing.

J_Rock · August 9, 2020, 3:08pm

I really like this article. I don’t think you’d find many consumers who would prefer to not know what’s in their wine, and I’m sure there are a good amount of consumers who are more likely to buy wine (especially quality wine) if they knew what was in it (and supposedly there’s at least one survey to support that).

K_N_Haque · August 10, 2020, 2:30am

Personally, I am not opposed to ingredients and also to nutritional info on a label. After all, you’ll find that on grape juice. And I would find it helpful calorie counts, because the general numbers are not helpful when you may be drinking a glass or two of 15% wine one day and then a 12.5% wine the next. Not to mention any sugar that affects things.

(And yes, I know there is a formula to calculate calories out there that is a combination of alcohol plus and RS, but, as Doug mentions above, why does wine get a pass on this type of info?)

Adam_Lee · August 10, 2020, 10:43am

Is chaptalization an “ingredient”?

Yes.

If it’s filtered through egg whites or casein, is that necessary to put on the label?

Those are fining agents, not filtering. If the finished wine has lab tests showing there’s none left in the wine, then it doesn’t need to be labelled. If there’s some in there, then it does.

Does cultured yeast mandate a mention?

I think it would depend on whether or not there’s any in the finished wine, but I am not sure on this one. I do think there’s an existing food labeling regulation that would say.

If a uses copper sulfate on the grapes, does that go on?

Again, lab tests decide.

All relevant, all matters of opinion.

I don’t think they are matters of opinion. The food industry already has a set of rules about ingredient labeling. The wine industry likes to pretend those rules don’t exist so they can create confusing arguments like this and avoid ingredient labeling. I’m not sure that all of my responses are correct in terms of those regulations, but the point is that this isn’t about opinion. Some mass produced non-alcoholic beverages also have relatively complicated methods of production and are sometimes treated with things that no longer exist in the finished product. Wine is not special because of these characteristics. I think all food and beverages, ESPECIALLY alcoholic drinks (the only thing I know of that’s exempt, and potentially one of the most dangerous thing legally sold to us as consumables) should have ingredient labels. I don’t think it would cause Millennials to drink more wine.

Why would chaptalization be an ingredient if the wine is fermented dry but other items which aren’t remaining in the wine (egg whites, etc.) don’t need to be listed?

Adam Lee

David_Bu3ker · August 10, 2020, 12:09pm

Is chaptalization an “ingredient”?

Yes.

If it’s filtered through egg whites or casein, is that necessary to put on the label?

Those are fining agents, not filtering. If the finished wine has lab tests showing there’s none left in the wine, then it doesn’t need to be labelled. If there’s some in there, then it does.

Does cultured yeast mandate a mention?

I think it would depend on whether or not there’s any in the finished wine, but I am not sure on this one. I do think there’s an existing food labeling regulation that would say.

If a uses copper sulfate on the grapes, does that go on?

Again, lab tests decide.

All relevant, all matters of opinion.

I don’t think they are matters of opinion. The food industry already has a set of rules about ingredient labeling. The wine industry likes to pretend those rules don’t exist so they can create confusing arguments like this and avoid ingredient labeling. I’m not sure that all of my responses are correct in terms of those regulations, but the point is that this isn’t about opinion. Some mass produced non-alcoholic beverages also have relatively complicated methods of production and are sometimes treated with things that no longer exist in the finished product. Wine is not special because of these characteristics. I think all food and beverages, ESPECIALLY alcoholic drinks (the only thing I know of that’s exempt, and potentially one of the most dangerous thing legally sold to us as consumables) should have ingredient labels. I don’t think it would cause Millennials to drink more wine.

Why would chaptalization be an ingredient if the wine is fermented dry but other items which aren’t remaining in the wine (egg whites, etc.) don’t need to be listed?

Adam Lee

0.00 g/l of residual sugar? (asking for a friend…)

DougS · August 10, 2020, 12:11pm

Just to reiterate, I’m not sure that all of my responses are correct in terms of the regulations, but I am confident that regulations do exist that would answer these questions. This one seems like common sense to me, though: sugar turns into alcohol, which remains in the wine. Neither the sugar nor its byproduct are removed, and the increased amount of alcohol can be significant (I don’t think it would be done for +0.01% ABV or something like that), so the sugar has significantly changed the makeup of the finished product.

An example that I think relates to fining agents is Velcorin, which doesn’t need to be listed as an ingredient in beverages. I would think fining agents would be viewed similarly.

I don’t know why this distinction wouldn’t be clear.

Sean_S_y_d_n_e_y · August 10, 2020, 1:21pm

I think more transparency is absolutely a good thing. But it would be pretty difficult to differentiate sugar that remained in the wine via chaptalization vs the sugars from the grapes. Ditto sulfites, which are used in the vineyard AND are a byproduct of fermentation AND used at various stages in the winemaking process from producer to producer. Added tannins or acid would be an interesting case too, because those obviously exist in wine naturally, so would every bottle have to list acid and tannin or just the ones that supplemented it? “Oak” for oak barrels or just oak chips?

It’s a fun discussion.

larry_schaffer · August 10, 2020, 2:34pm

What about if you use reverse osmosis to remove alcohol? Or micro-filtration? Or flash pasteurization? I know these aren’t ingredients, but wouldn’t you want to know?

DougS · August 10, 2020, 3:15pm

Why does one need to differentiate between grape sugars and added sugars? If sugar is added, it is an ingredient. If only grapes are added, the grapes are the ingredient. It really doesn’t matter what’s left in terms of RS to decide whether or not sugar was an ingredient. Same thing with sulfites, tannins, and acid. They’re added as individual ingredients or they’re not. So, no, every bottle wouldn’t have to list those, only wines that had separate additions of those things. Again, it’s the same with food. A bottle of grape juice doesn’t list every chemical compound within the grapes. I don’t know about oak, but there are definitely food products aged in oak, so I’m sure there’s some precedent there. I don’t know why chips would be different from barrels.

I think the industry has convinced a lot of people that this is far more complicated than it actually is, seemingly because some members REALLY don’t want to tell consumers what they add to the must/wine. If one can take a step back and think of the wine as a food product that should be labelled as such (I have never seen a rational argument to the contrary), it’s not any more complicated than it is with many existing non-alcoholic beverages and foods. They all manage to list ingredients.

DougS · August 10, 2020, 3:17pm

I’d like to know, but I don’t think there’s any reason for those to have to be stated. Nothing has been added to the wine. Some of those things are done with juices and such, and they are not stated on the label. I think this is an interesting hypothetical that isn’t related to ingredient labeling.

Ben_M_a_n_d_l_e_r · August 10, 2020, 4:26pm

I do think it’s an interesting conversation, especially when you get into winemaking products that are derived directly from grapes. Tartaric acid, grape seed tannin, grape juice concentrate - these are natural components of grapes that are industrially concentrated - from grapes - and then added back to wines in concentrated form. These are grape components added to grapes. Should a winery then be made to disclose all modifications they make to the “pure grape”? If a winery adds 1% Petite Sirah to their Pinot Noir to increase its color density, should they have to disclose that? What about if a winery bleeds 10% of their juice off to concentrate flavors in their reds? These might seem obviously different to some people and not to others, and it’s not immediately clear what line to draw and where.

This is especially true with fining agents. Fining agents do leave small quantities remaining in the wine, but again we’re getting complicated. There is trace bentonite in many unfined, unfiltered wines, because clay dust gets onto grape skins in the vineyard and we don’t wash the grapes! Not 100% of that clay ends up in the lees, whether it comes from the vineyard or fining - it’s pretty damn close to 100% either way, but it’s not 100%. I understand that a vegan would be concerned about the use of casein, isinglass, etc. but vegan is, and presumably always will be, an opt-in labelling choice, not a mandatory one.

Changing tack, let’s take copper sulfate as an example. Maybe labelling laws change so that you have to report if you add copper sulfate. How is that then legislated? Do you have to report if you add any copper sulfate? If so, why? Is it like sulfites, in that people want assurance that the copper concentration is below a certain threshold? In which case you then have to consider natural variation in copper in wines, as well as copper spraying in the vineyard. Or is the reason for wanting labelling simply that something is being artificially added? In which case, do you have to report if you use copper mesh instead of adding copper sulfate solution directly to the wine?

These are a few examples off the top of my head but I am sure that there are many more. People are fond of saying “it’s not that complicated” but it is complicated. Not intractable, but complicated.

Adam_Lee · August 10, 2020, 5:53pm

I think more transparency is absolutely a good thing. But it would be pretty difficult to differentiate sugar that remained in the wine via chaptalization vs the sugars from the grapes. Ditto sulfites, which are used in the vineyard AND are a byproduct of fermentation AND used at various stages in the winemaking process from producer to producer. Added tannins or acid would be an interesting case too, because those obviously exist in wine naturally, so would every bottle have to list acid and tannin or just the ones that supplemented it? “Oak” for oak barrels or just oak chips?

It’s a fun discussion.

Why does one need to differentiate between grape sugars and added sugars? If sugar is added, it is an ingredient. If only grapes are added, the grapes are the ingredient. It really doesn’t matter what’s left in terms of RS to decide whether or not sugar was an ingredient. Same thing with sulfites, tannins, and acid. They’re added as individual ingredients or they’re not. So, no, every bottle wouldn’t have to list those, only wines that had separate additions of those things. Again, it’s the same with food. A bottle of grape juice doesn’t list every chemical compound within the grapes. I don’t know about oak, but there are definitely food products aged in oak, so I’m sure there’s some precedent there. I don’t know why chips would be different from barrels.

I think the industry has convinced a lot of people that this is far more complicated than it actually is, seemingly because some members REALLY don’t want to tell consumers what they add to the must/wine. If one can take a step back and think of the wine as a food product that should be labelled as such (I have never seen a rational argument to the contrary), it’s not any more complicated than it is with many existing non-alcoholic beverages and foods. They all manage to list ingredients.

David,

I disagree. Adding sugar and having the wine ferment dry (no not 0.0g/l that’s not the current standard of dry) means that no more sugar was left in the wine than would have been left had the wine not had that addition. Same goes for tartaric, etc. What you want isn’t an ingredient listing as per what the FDA does - but rather an added ingredient labeling - something that the FDA does not require (like your velcorin example).

Why is the wine different than other food products? In part because of the fact that, when Prohibition was repealed, the regulation of alcohol was placed uniquely in the hands of the states in addition to the federal government. So I have to pay licensing fees to various states for various labels ($1000 per label to Connecticut for example). I have had labels that have been approved by the TTB rejected by Alabama, as another example.

Finally, wine is different from food in that it has vintages associated with it. That alone means that decisions are different each year as opposed to the maker of orange juice for instance. So having to get a new label approval each vintage from the states that require state label approvals if one year you put down “tartaric acid” as an ingredient but the next year you don’t would be ridiculously expensive for smaller wineries. And you would end up with what you have in the orange juice world - where a few major companies control the entire process.

I would be fine with a requirement to have it listed on the website - where states don’t get to charge us for annual changes.

Adam Lee

David_Bu3ker · August 10, 2020, 6:39pm

David,

I disagree. Adding sugar and having the wine ferment dry (no not 0.0g/l that’s not the current standard of dry) means that no more sugar was left in the wine than would have been left had the wine not had that addition. Same goes for tartaric, etc. What you want isn’t an ingredient listing as per what the FDA does - but rather an added ingredient labeling - something that the FDA does not require (like your velcorin example).

Why is the wine different than other food products? In part because of the fact that, when Prohibition was repealed, the regulation of alcohol was placed uniquely in the hands of the states in addition to the federal government. So I have to pay licensing fees to various states for various labels ($1000 per label to Connecticut for example). I have had labels that have been approved by the TTB rejected by Alabama, as another example.

Finally, wine is different from food in that it has vintages associated with it. That alone means that decisions are different each year as opposed to the maker of orange juice for instance. So having to get a new label approval each vintage from the states that require state label approvals if one year you put down “tartaric acid” as an ingredient but the next year you don’t would be ridiculously expensive for smaller wineries. And you would end up with what you have in the orange juice world - where a few major companies control the entire process.

I would be fine with a requirement to have it listed on the website - where states don’t get to charge us for annual changes.

Adam Lee

Adam,

Apologies for the lack of a sarcasm font. The 0.0 was a reference to another discussion about “dry” wines.

The labeling issue is a huge one, and makes the specificity almost impossible. Sure there could be a bit of generic text about the general process and the elements thereof, but then some smart ass on Berserkers would call you out for that.

DougS · August 10, 2020, 10:23pm

I disagree. Adding sugar and having the wine ferment dry (no not 0.0g/l that’s not the current standard of dry) means that no more sugar was left in the wine than would have been left had the wine not had that addition. Same goes for tartaric, etc. What you want isn’t an ingredient listing as per what the FDA does - but rather an added ingredient labeling - something that the FDA does not require (like your velcorin example).

Why is the wine different than other food products? In part because of the fact that, when Prohibition was repealed, the regulation of alcohol was placed uniquely in the hands of the states in addition to the federal government. So I have to pay licensing fees to various states for various labels ($1000 per label to Connecticut for example). I have had labels that have been approved by the TTB rejected by Alabama, as another example.

Finally, wine is different from food in that it has vintages associated with it. That alone means that decisions are different each year as opposed to the maker of orange juice for instance. So having to get a new label approval each vintage from the states that require state label approvals if one year you put down “tartaric acid” as an ingredient but the next year you don’t would be ridiculously expensive for smaller wineries. And you would end up with what you have in the orange juice world - where a few major companies control the entire process.

I would be fine with a requirement to have it listed on the website - where states don’t get to charge us for annual changes.

Adam Lee

I could be wrong about the sugar if fermented to dryness, but that doesn’t negate my point. I’m not saying the standards should be different from the food standards, and I’ve said multiple times that I am not sure about the details of those. I am not here to decree what the standards should be.

Why couldn’t it be one national approval for ingredients only? Right now the states require nothing. That wouldn’t have to change. How much would the single national approval cost each year? Even if that couldn’t work, I like the alternative you’ve proposed. I’d be fine with it being on the website instead of the bottle too. Everyone has a computer in their pocket these days. I think that’s a great solution.

I appreciate the details from your perspective. There are elements here that I hadn’t considered. I do still think they are easily solvable and that the lack of a requirement for ingredient labels or statements on all alcoholic beverages is ridiculous.