Wine ingredient labeling

From a bug POV you are correct. But the mentions of velcorin being on a wine label would, in fact, be holding wine to a higher standard that other food labels. Sulfite listings are already a higher standard than food labeling as well.

Adam Lee
Siduri Wines

I don’t think everyone is advocating labeling velcorin either. There’s the one “anything in a bag or box” post, but seems to me more sensible to start with the same standard as Gatorade.

No-But if the labels are approved, you will see some later this year… I just need fold out back labels for all those danged ingredients :wink: (just kidding)

I don’t see anyone doing that either. It’s just another straw man (those wine-labelling advocates are all raving fanatics!). I did mention Velcorin earlier, which is not fessed up to in food labelling and I think should be. Otherwise, I personally think that food labeling laws are a perfectly adequate standard…

Katrina,

I am sorry, but which food labeling laws are a perfectly adequate standard? They are different based on the food (calorie counts, for instance, based on the size of the restaurant preparing the food, fresh food vs. pre-prepared food, etc). Gatorade labeling rules are different than orange juice labeling rules. I know it sounds like I am being obsequious, and perhaps I am, but I’ve actually spent a decent amount of time looking around the CFRs on all of these items, and the differences are occasionally pretty stunning.

Adam Lee
Siduri Wines

Cool. I look forward to it. So, with your goal of letting the consumer know what is in the wine, are you labeling something like tartaric acid?

Adam Lee
Siduri Wines

Not obsequious. Possibly obstreporous :slight_smile:

All I said, and all I mean, is that I am not personally advocating for wine label ingredients (on a bottle, on a shelf, in a store) to be held to a higher standard than tomato sauce (in a jar, on a shelf, in a store).

Labeling. (i) The name of the food is:

(a ) “Tomato puree” or “tomato pulp” if the food contains not less than 8.0 percent but less than 24.0 percent tomato soluble solids.

(b ) “Tomato paste” if the food contains not less than 24.0 percent tomato soluble solids.

(c ) The name “tomato concentrate” may be used in lieu of the name “tomato puree,” “tomato pulp,” or “tomato paste” whenever the concentrate complies with the requirements of such foods; except that the label shall bear the statement “for remanufacturing purposes only” when the concentrate is packaged in No. 10 containers (3.1 kilograms or 109 avoirdupois ounces total water capacity) or containers that are smaller in size.

(d ) “Concentrated tomato juice” if the food is prepared from the optional tomato ingredient described in paragraph (a)(1)(i) of this section and is of such concentration that upon diluting the food according to label directions as set forth in paragraph (a)(3)(iii) of this section, the diluted article will contain not less than 5.0 percent by weight tomato soluble solids.

(ii) The following shall be included as part of the name or in close proximity to the name of the food:

(a ) The statement “Made from” or “Made in part from,” as the case may be, “residual tomato material from canning” if the optional tomato ingredient specified in paragraph (a)(1)(ii) of this section is present.

(b ) The statement “Made from” or “Made in part from,” as the case may be, “residual tomato material from partial extraction of juice” if the optional tomato ingredient specified in paragraph (a)(1)(iii) of this section is present.

(c ) A declaration of any flavoring that characterizes the product as specified in 101.22 of this chapter and a declaration of any spice that characterizes the product, e.g., “Seasoned with ___,” the blank to be filled in with the words “added spice” or, in lieu of the word “spice,” the common name of the spice.

(iii) The label of concentrated tomato juice shall bear adequate directions for dilution to result in a diluted article containing not less than 5.0 percent by weight tomato soluble solids; except that alternative methods may be used to convey adequate dilution directions for containers that are larger than No. 10 containers (3.1 kilograms or 109 avoirdupois ounces total water capacity).

(iv) Label declaration. Each of the ingredients used in the food shall be declared on the label as required by the applicable sections of parts 101 and 130 of this chapter; except that water need not be declared in the ingredient statement when added to adjust the tomato soluble solids content of tomato concentrates within the range of soluble solids levels permitted for these foods.

(v) Determine percent tomato soluble solids as specified in 155.3(e). Determine compliance as specified in 155.3(b). A lot shall be deemed to be in compliance for tomato soluble solids as follows:

(a ) The sample average meets or exceeds the required minimum.

(b ) The number of sample units that are more than 1 percent tomato soluble solids below the minimum required does not exceed the acceptance number in the sampling plans set forth in 155.3(c)(2).

(b) Quality. (1) The standard of quality for tomato concentrate (except for concentrated tomato juice, which when diluted to 5.0 percent tomato soluble solids shall conform to the standard of quality for tomato juice set forth in 156.145 of this chapter) is as follows:

(i) The strength and redness of color of the food, when diluted with water (if necessary) to 8.1+/-0.1 percent tomato soluble solids is not less than the composite color produced by spinning the Munsell color discs in the following combination:

53 percent of the area of Disc 1;

28 percent of the area of Disc 2; and

19 percent of the area of either Disc 3 or Disc 4; or

9 1/2 percent of the area of Disc 3 and 9 1/2 percent of the area of Disc 4, whichever most nearly matches the appearance of the sample.

(ii) Not more than one whole seed per 600 grams (21 ounces).

(iii) Not more than 36 of the following defects, either singly or in combination, per 100 grams (3.5 ounces) of the product when diluted with water to 8.1+/-0.1 percent tomato soluble solids:

(a ) Pieces of peel 5 millimeters (0.20 inch) or greater in length (without unrolling).

(b ) Pieces of seed (seed particles) 1 millimeter (0.039 inch) or greater in length.

(c ) Blemishes, such as dark brown or black particles (specks)–not more than four exceed 1.6 millimeters (0.0625 inch) in length of which not more than one exceeds 3.2 millimeters (0.125 inch) and none exceed 6.4 millimeters (0.25 inch).

(2) Methodology. Dilute with water, if necessary, to 8.1+/-0.1 percent tomato soluble solids. (i) Determine strength and redness of color as prescribed in 155.3(d).

(ii) Whole seeds–Weigh out 600 grams (21 ounces) of the well-mixed, diluted concentrate; place a U.S. No. 12 screen (1.68 millimeters (0.066 inch) openings) over the sink drain; transfer the product sample onto the screen; rinse container thoroughly with water and pour through screen; flush sample through screen by using an adequate spray of water; check screen for whole seeds; apply the appropriate allowance.

(iii) Peel, pieces of seed, and blemishes–Spread the prepared concentrate evenly on a large white tray and remove the individual defects, identify, classify, and measure.

(3) Sampling and acceptance. Determine compliance as specified in 155.3(b).

(4) If the quality of the tomato concentrate falls below the standard prescribed in paragraph (b) (1) and (3) of this section, the label shall bear the general statement of substandard quality specified in 130.14(a) of this chapter, in the manner and form therein specified, but in lieu of such general statement of substandard quality when the quality of the tomato concentrate falls below the standard in one or more respects, the label may bear the alternative statement, “Below Standard in Quality ___,” the blank to be filled in with the words specified after the corresponding paragraph(s) under paragraph (b)(1) of this section which such tomato concentrate fails to meet, as follows:

(i) “Poor color.”

(ii) “Excessive seeds.”

(iii)(a ) “Excessive pieces of peel.”

(b ) “Excessive pieces of seed.”

(c ) “Excessive blemishes.”

(c) Fill of container. (1) The standard of fill of container for tomato concentrate, as determined by the general method for fill of container prescribed in 130.12(b) of this chapter, is not less than 90 percent of the total capacity, except when the food is frozen.

(2) Determine compliance as specified in 155.3(b).

(3) If the tomato concentrate falls below the standard of fill prescribed in paragraph (c) (1) and (2) of this section, the label shall bear the general statement of substandard fill specified in 130.14(b) of this chapter, in the manner and form therein prescribed.

Ahhh…I see…I can’t wait. We will all be broke…

Adam Lee
Siduri Wines

yes. I’m sure you’ll all end up in receivership just as happened to all those myriad food producers who went belly up after the passage of food labelling laws.

Funny how the argument against labeling keeps shifting though isn’t it?

it’s too expensive
consumers don’t care
consumers will be confused
wine is too special a beverage to be subjected to this kind of analysis/description
government always screws up and they will here too
the label is too small

So Adam, are you saying we should not force ingredient labels on tomato sauce?

Michael

Katrina,

Since Hardy wouldn’t do it, how about answering all the questions I posed to Hardy? Give us something concrete. Tell us how specifically it should work. And please, respond to Mike Evans’ post.

That’s just not true. The argument isn’t shifting. As you bring up more naive points, it becomes necessary to refute those as well.

FWIW,

it’s too expensive (yes, it is. Not just for producers but also for consumers that are going to be subjected to increasing prices due to this.)
consumers don’t care (I never said that)
consumers will be confused (I think they will be)
wine is too special a beverage to be subjected to this kind of analysis/description (no,that wasn’t argued by anyone. Wine’s special-ness when it comes to labels is because of the repeal of prohibition and states being given the regulation of alcohol within their borders)
government always screws up and they will here too (they do often, but as you pointed out, sometimes what they do is better as well, when there is true abuse and health issues involved. Not the case with wine)
the label is too small (didn’t see that mentioned here personally)

As far as receivership for the food producers…take a look at the number of orange juice producers…one company has 65% of the market. And there are only a handful of producers out there truly (most buy the juice from others). Same is true for many juice producers. The wine business, on the other hand, is thriving with many small companies, such as Hardy’s, Larry’s, Mike’s, Brian’s, etc.

The tomato regulations that I quoted from above would drive them all out of business. Not hyperbole, not exaggeration. They would not exist.

Adam Lee
Siduri Wines

I am saying that the regulations above do not allow for smaller companies to easily participate in the market, as opposed to wine, which does allow it. Say Hardy was told that his whole cluster Mourvedre was too light in color and had to be labeled as inferior in quality because of that (part of the tomato regulations). Let’s ask him, Hardy…how would that make you feel?

Adam Lee
Siduri Wines

The argument absolutely does keep shifting. You didn’t engineer all of those shifts, but plenty of them.

Orange Juice producers as an analogy for wine-producers? Seriously? Until we can talk about different kinds of orange juices and how Floridian terroir exhibits itself in orange juice differently than Valencian terroir (and have consumers make choices based on those differences), the analogy doesn’t hold. Those producers went out of business becaurse it’s a monolithic product subject to monopolistic ownership (just like ATT and Verizon shoved most every other provider out of the phone business.)

You could just as easily talk about the many small producers who were enabled to prosper in the food industry JUST BECAUSE of those food labeling laws. The Amys and the Hains and the Celestial foods and the Numi teas and Lundberg organic farms and the myriad others that were able to capitalise on consumer’s desire for less manipulated foods.

The Amy’s founders had money from food investments prior to labeling laws, which allowed them to start Amy’s. It has thrived because the found a niche’ of people who want their product. But they started with coin (unlike many of us in the wine business). The Hain folks falsely labeled many of their products to say they were organic and are being sued in a class action lawsuit because of the high levels of pesticides in their products. — You’ll have to do better than that.

You said you wanted the standard for wine to be the same as tomato sauce. So are you in favor of color standards for wine? Are you wanting wineries to adhere to the Munsell color disc technology to measure that color? Do you want wineries who don’t filter to have to label their product as inferior using the same standards as tomato sauce producers? These are real questions, using the standard you advocated.

I am not in favor of these standards. I don’t like some of the wines I’ve had that have more sediment in them than I want. I don’t like some of the wines I’ve had that are too light in color (or some that are too dark in color). But I’d never want them labeled as inferior because of such labeling laws.

Adam Lee
Siduri Wines

Gossip about particular artisanal food producers aside, are you arguing that increased consumer awareness (arising in part from food labelling laws) did and does NOT provide a niche for new food producers? Then you’ll need also to dig some dirt on Numis, Lundberg farms, Organic Valley, Eden Valley, Traditional Medicinal teas etc etc etc and discredit those. Probably won’t be too hard to discredit Whole Foods though there is no question that a walk down their aisles will turn up so many thriving new artisanal food producers that you’ll have to hire an army of dirt dishers to make your case.

In short, there are many small wine producers who stand to benefit from labelling and increased consumer education. It’s something that can be capitalized on, even as it imposes new costs and headaches.

Would you please answer my questions about tomato color and clarity standards and how it pertains to labeling? That’s the regulations you were advocating. I don’t think those would help smaller wineries in any way.

Adam Lee
Siduri Wines

Adam, cool it with the straw man. People are talking about ingredients, not color. There are already regulations about what you can label mourvedre.

Michael

You are again creating a straw man and putting words in my mouth. What I said was that food labeling laws are a good model --since they are the closest model we have – for wine labeling laws. And I said that in the context of refuting the idea (from Buecker) that wine-label advocates are fanatical over-reachers who would go further than the food laws do.