Vine Wise
“For every complex problem there is an answer that is clear, simple and wrong.” —H. L. Mencken
T oday, I want to write about nutritional and ingredient labeling as it relates to wine. These issues have been discussed for almost 20 years. In 2005, the Alcohol and Tobacco Tax & Trade Bureau (TTB) sought comments from the public about nutritional and ingredient labeling on wines—deciding at the time not to take any action. In 2008 Bonny Doon Vineyard in Aptos began listing its own version of ingredients on the label, with Ridge Vineyards following. Since then, a handful of other wineries have followed suit. The current interest in nutritional and ingredient labeling The true cost of ingredient labeling By Adam Lee
yeasts” as an ingredient in that wine—and a winemaker’s yeast choice is certainly something that wine lovers want to know. However, if you look at the tech sheet on the wine you will see that the wine was “pad filtered at bottling” meaning that the yeast was filtered out. No longer is that yeast an ingredient in the wine. There are many other similar examples. The problem is not that Ridge Vineyards (or any winery listing ingredients) is being dishonest. They are incredibly well meaning. However, summarizing 12-24 months of winemaking in the tiny spot provided on a label is difficult. It necessitates taking
is being driven by new EU requirements on wine being made or sold in the European Union. Subsequently, in February of 2024, the TTB opened hearings and public comments on nutritional and ingredient labeling requirements on wines produced in the United States. From the outside it seems like a simple subject with those who favor such labeling as “the good guys” and those who oppose it as “the bad guys.” In reality, it is a good bit more complex. To fully understand the situation, it is important to note the differences between nutritional information and ingredient labeling. Nutritional information includes listing the calories, carbohydrates, fat and proteins in each wine along with, possibly, sugars and alcohol (which is already
short cuts and omitting some information in favor of other information. Add to this that wineries need to print labels months ahead of time and submit them to the TTB for approval and you could easily see a situation where a winemaker decides to make a last-minute addition to their wine prior to bottling to improve the wine and the label is no longer accurate. Another factor: wine is not regulated simply by the federal government. Thanks to the wording and interpretation of the 21st Amendment, states have authority to regulate the importation of alcohol. It is not difficult to imagine the neo-prohibitionist movement in certain states placing further requirements on labeling or even prohibiting importing wines with certain ingredients listed.
required). It most likely also includes listing any allergens in a wine. Ingredient labeling involves listing the actual ingredients in a wine and, perhaps, the list of additions made to the wine. Let’s begin by looking at one component—calories in wine—something you would think would be simple. Most calories in wine come from alcohol. Lower alcohol (12%) wines contain around 120-125 calories per serving while higher alcohol (15% wines) contain around 180-185 calories per serving. That’s not a huge difference but perhaps one worth noting. That is, until you realize that current FDA guidelines allow for 20% leeway when calculating calories. Knowing that, it seems that virtually every wine could label itself as having 150 calories and be legal. Carbohydrates and proteins in wine are so small and allow for a similar 20% margin of error that listing them would also seem to be useless—and wine doesn’t contain fat so that is most definitely unnecessary. What would it cost a winery to provide this useless information? Currently, ETS Labs charges $400 per sample for this testing. For a single wine that doesn’t seem to be ridiculously expensive, but one of the endearing aspects of the wine business is the mom-and-pop winery that produces small lots of varying wines in their garage winery. When I owned Siduri Wines and made wine in a warehouse, I produced upward of 40 different wines with production as small as 50 cases. 40 wines times $400 adds up to $16,000, and that hits hard. Ingredient labeling is surprisingly complicated. The very word “ingredient” is defined by online dictionaries as a “component part or element of something.” That seems simple. Ridge Vineyards on its Estate Chardonnay, for example, lists “indigenous
Having said this, I do believe there is a solution to these issues, and it was provided to us by COVID. During the pandemic, many of us became accustomed to using a QR code. Rather than letting the federal government mandate an expensive and sometimes meaningless solution, wineries could use QR codes that take consumers to a page where all additions and ingredients are fully listed. There a winery can be as detailed as it wants to be about its winemaking, describing for consumers not only what it did, but why it did it. This proactive solution would allow winemakers to make changes to the wine until the last minute and would eliminate the potential involvement of state liquor agencies. California wineries are already having to change their labels by adding redemption value (CRV) information on or before July 1, 2025. It would benefit us all if we could come together as wineries and tell the TTB that we are going the route of the QR code and placing that on our labels at the same time. Being proactive now might save us all a huge headache later.
Adam Lee co-founded Siduri Wines in 1994, selling it to Jackson Family Winery in 2015. He now produces and owns Clarice Wine Company, and consults with numerous different wineries, including Rombauer Vineyards on their Pinot Noir project.
March 2024
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