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

WINE TALK
21

Doug,

The question is whether or not the states would be willing to give up their control in favor of a national standard for ingredient labeling. And whether or not you want wine to be made like other mass produced beverages. For a very small client, just recently, they asked to trial a very small acid addition a couple of weeks prior to bottling. We did that and they decided to make that addition. We then racked the wine into tank and tested the SO2 levels after that and saw that the wine needed an additional sulfur addition. After making that addition, the wine seemed to tighten up a bit, so we didn’t make the acid addition after all. How could this winery print accurate labels? Do you want to take away their ability to make those decisions (which would be different in 2019 than in 2018, for instance). I personally don’t want wine to be made like Coca-Cola where there is one standard recipe. I want it to be different and want wineries to be able to make those decisions. Printing labels is usually, at least 6 weeks before bottling.

My thought is the website is the way to go - then you can adjust it to be accurate. Doesn’t address the standards that would be used - but addresses a lot of the extra cost to wineries and allows them to make wine in an artisinal manner.

Adam Lee

22

As Adam already pointed out, its not just the additional cost of label approval fees, its everything else associated with it as well (leading to more costs). Like art work, ingredients list really, that may/will need to be changed each and every release/bottling/bottle. In order to start a label approval process one needs lab results first. As pointed out above, things change, on the fly sometimes, even with best laid out plans.

Wine is not a “formulaic” product, as are most other foods. Even at large(r) wineries. There is no “add X grams of Y, and Z grams of D, and…” recipe. Vintage matters. And even those of us who are reluctant to do anything with the wine save for SO2 adds may be forced by nature to react, if not often enough, then at least once in a blue moon, even with a simple task of acidulation (I haven’t done it in years, but am not against it if forced to).

Here is the cycle one needs to go through with all this discussed/proposed newfangled “wine ingredients list”:

In order to get this started, one needs to have final blends. And as Adam pointed out, sometimes things change, at the last minute. Once final blends are done, one needs lab results. With labs, all of a sudden, overloaded with more testing.

Once lab work is done, one gets to the really, hmmm, “interesting” and challenging part where labels’ text needs to be refactored before label approval submission. I have no idea how much people know about dealing with “artists” and their own schedule of “I see it this way, and do not rush me!”, so its anyone’s guess, especially when this step will also overload “artist” community. I have yet to find one who is reliable, time wise at the least, so feel free to let me know of one. Main reason I have learned PS and Illustrator on my own and do my own work now, since its the only way to ensure timing. How many other small wineries do?

But let’s move on. Once your artist decides to finish the masterpiece and turn it over to you, which could be weeks on the quick side, one needs to submit for label approval, each and every release, for each of the wines to be bottled. Throwing government bureaucracy into the mix. Timing, again. And, same as labs, with a very increased work load, what could go wrong, its just a government agency, right? Never mind additional cost of art work, for each label that started the process, and that may need to be repeated if your label is not approved (not just extra cost, but extra time, again).

Then, and only after you KNOW when your labels have received approval one must provide printer houses with at least a 5 weeks head start to have print date scheduled.

And with all of these extra steps one would hope that a bottling date is not blown, who knows when next one comes up. Miss one and your wine will sit in tanks until next bottling date is available. And those tanks may be needed for next crush. Its a never ending “What if?” scenario for an industry that simply cannot depend on a “formula recipe” production, like others.

All the while all other products made via formula recipe just do all of this once. And simply repeat the recipe going forward.

Its a whole new world that most consumers really do not understand, or rather, may understand only parts of it. The small details that are really not that small in the end, and when one blows up your entire timeline goes with it. And costs. Some large wineries may be fine with all of that, small guys will go out of business as this entire scenario is not sustainable in the long run. Unless wine prices escalate to cover all additional time and cost. And even then…

And, then, to point out the obvious, just how much do you guys think is really disclosed in this just announced “clean” wine by Cameron Diaz, as one recent and obvious example? What have they really disclosed, in reality? What about all the EU wines that claim to be not chaptalized, not watered (vineyard), not acidulated, not ROed, and listing ~13% alc when in reality they may be 15-16%? Only because there is a new law, or whatever, doesn’t mean that some won’t ignore it as they have been, for decades.

23

I just spent a few minutes looking into this, and it seems to me that there is only a federal standard for ingredient labels. I see that several states enforce the federal standard, as they are allowed to do, but I can’t find any state licensing for ingredient labels, only the federal one. Am I missing something? I think this is a non-issue.

24

There is no federal standard for “ingredient labeling.” That’s why Ridge does things very different from Bonny Doon in their listings. Bonny Doon adds oak, Ridge doesn’t. Ridge adds indigenous malolactic bacteria, Bonny Doon doesn’t. I don’t know what you saw - alcohol perhaps or sulfur? Those have become federal issues - although alcohol can be state or even county issues from a sales point of view (where you can sell the wine). But there are no standards for ingredient labeling.

Adam Lee

25

Not sure what problem(s) people want to solve. The OP was mostly motivated by “clean wine”. From Alder Yarrow’s Vinography blog,

"‘Clean Wine’ is a Commercial Scam’

-Al

26

I mean for food. If alcoholic beverages would follow the same system as all other beverages (what I’ve been suggesting all along), it appears that there wouldn’t be issues with a bunch of individual state regulations or licensing, only one federal system. Again, the fact that different wineries have different opinions on what constitutes an ingredient is not relevant to what I’m saying.

27

Doug, and what I am saying is that the US Constitution gives states the right to control alcohol within state borders to the states. Turning those regulations over to the FDA, which has no basis right now to regulate such things, would surely be challenged by states as un-Constitutional.

Adam Lee

28

I see. That is a bizarre complication, but it does seem to be true.

29

I agree with GregP. Will the EU comply? I’m guessing not.

30

The TTB now has something to say about “clean” wine marketing:

https://www.ttb.gov/images/newsletters/archives/2020/ttb-newsletter08142020.html

Not that different from how that FDA approaches health claims.

31

Do you get calorie info from your restaurant (other than fast food)? Ironic that fast food was vilified for calorie content but sit down restaurants get a pass on desserts with mega calories. Which brings up the point of the burden of calorie counting for smaller operations. Easy for Gallo, not so easy for Sandlands, etc. when there is only a barrel or two.

32

Here is what the average red wine label of ingredients would be if ingredient labeling was mandatory…

INGREDIENTS: Grapes, Clear Alcohol Reducer, Sulfur Dioxide, Potassium Metabisulfite, Tartaric Acid, Diammonium Phosphate, Saccromyeces Cerivisea, Yeast Nutrient, Oenococcus Oeni, Enzymes, Copper Sulfate Pentahydrate

This product was manufactured in the vicinity of nuts

33

Present company included [wink.gif]

34

Fair point. No, in my state only the chains have the list cals. But as I understand it, wine calories can be calculated from alc. % and RS. Presumably the winemaker has that info. You’ll notice I did not say I want to require this, it’s just a preference, but it does seem easier to calculate for a small winery than for a small restaurant where a dish has multiple ingredients, especially sine I expect Sandlands and the like to just be using grapes and yeast (and I am not one who would be in favor of seeing fining agents. on a label).

35

I referred to you, but my complaint is more general about restaurants and calorie counting. I agree we need some more info on wine content like sugar levels. Certainly one frustrated Riesling drinker would agree.

36

The most important other component is glycerol, which is about 4 cal/g and is typically present at around 5-10 g/l. Most winemakers do not measure glycerol content, though an approximate number could be guessed at. Not sure what the requirements are regarding labelling accuracy for calorie content.

37

Personally I’m more interested to achieve transparent labelling around varietal, vintage, aoc decisions. Baby steps…

38

Thanks. I never thought of glycerol having calories! I wonder what I thought it contained?! I have never seen a glycerol content listed for a wine and never heard it discussed except as pertains to moutfeel and how the wine adheres to the glass (ie. “legs.”)

39

Yup! It’s also sweet - about 60% as sweet as table sugar - and its sweetness is perceptible above around 5 g/l, which is part of the reason that dry wines don’t taste punishingly dry. The fact that glycerol is (a) produced by fermentation, and (b) produced at higher rates in high-sugar musts to protect the yeasts, is part of the reason why “dry” higher alcohol wines like Zinfandel may have higher perceived sweetness or fruitiness (another being that high-sugar musts are difficult to fully ferment, commonly leaving some residual sugar, especially fructose).

40

It will be very interesting to see if this gets enforced, and how.