Read your whole post above.
Are there European wines coming in above the stated alcohols and also outside of the margin of error mandated by the TTB?
Probably so. And by that I mean that I would bet $1000 that it is happening and in some regions with reasonable frequency.
Does that mean that all European wines are that way?
Probably not. And I would bet $50,000 on that every time the bet was offered.
There may be quite a few occurrences of that but you can’t just use the possibility/probability of those wines existence to blanket the continent. Nore to suggest that posters here are too ignorant to seek out lower abv bottles by more than just the numbers.
That said, I was in a wine shop in Portland in 2005 and the shop owner was looking at a bottle and exclaiming about how a mutual favorite producer always managed to make wines of 12.5%, even in baking hot vintages like 2003…I know the producer and he’s retired now but he never bothered to change the abv on the label regardless of vintage.
So, I’m in your camp regarding truth in labeling for abv.
Though just for your own education, you do not need to re-submit a COLA for a change in abv unless you cross the tax line. If you do cross the tax line, you would submit a new COLA but your previous one would still cover any future vintage where you wound up back on your original side of the tax line. i.e. you only need a COLA for a label above 16% and a COLA for the same wine below 16%. You don’t need to re-submit each year.
Last, I make 4000+ cases a year. And I can tell you that out of shiners with no label on them, I like the vintages with lower alcohol enough that it is the FIRST and FOREMOST thing I am focused on. Picking ripe fruit at Brix levels that without watering back will give me sub 14% abvs and sub-13% if I can. We’ve changed our farming drastically to accomplish this, and had pushback from every grower until they have the wines.
You have your world and I respect your work, and Larry’s as well. But liking lower alcohol isn’t just being fooled by labeling allowances. And I am not all knowing in this, but I am also not ignorant of the subject.