Wine: Should the government clarify labels?
When you look at a wine label, do you get perplexed by terms such as Proprietor's Reserve or Barrel Select? What do those barrels select, precisely? How old do vines need to be before they become “Old Vines”? (That's a touchy subject in some demographics!) Does the word “Estate” mean anything to you, aside from estate planning?
You're not alone if you wonder about these things. The Treasury Department's Alcohol and Tobacco Tax and Trade Bureau (TTB), the successor to the old Bureau of Alcohol, Tobacco and Firearms (ATF) wants to know, too. In a (PDF alert) Federal Register notice published early this month, the TTB asked for public comment on whether it should amend its regulations to give precise meaning to these and other terms. The notice is worth reading, and as far as Federal Register literature goes, it's a spell-binder.
There is some reading between the lines to do, however. For example, the TTB notes that industry petitioners have asked the agency to distinguish between “estate bottled” and “estate grown.” The first term is enshrined in TTB regs to mean that the wine is grown in vineyards owned or controlled by the winery in a designated American Viticultural Area, and that the winery controls all aspects of the vinification from fermentation through bottling, on the premises. TTB policy – but not regulation – has held that “estate grown” should mean the same thing, so consumers don't get confused. The proposed change would allow a wine that does not meet the current standard for “estate bottled” to be labeled as “estate grown.”
What's the difference? It could be something as simple as whether a small winery that owns its vineyard and uses only its own fruit also owns a bottling line – or uses a contractor to bottle, therefore saving money but losing the “estate” label. Or it could allow a winery that controls the process from start to finish but is not in an established AVA to call its wine “estate grown.” Boxwood Winery near Middleburg, for example, does not meet the “estate bottled” criteria because it is not located in one of Virginia's six established AVAs. Yet the winery uses only grapes grown on its estate, and controls the vinification and bottling. For all intents and purposes, its wines are what discerning consumers think of when they see the word “estate” on the label.
On the other hand, if TTB is not careful, it could allow “estate grown” to mean anything, and thus nothing. The agency notes that it already allows the use of the words “estate” and “estates” on wine labels without the need to satisfy the criteria for “estate bottled”; it is asking whether it should specify definitions of those words as well.
In general, I favor clarity and specificity in wine labeling terms, as an aid to the consumer in sorting through all the marketing hype. So does the TTB. That's why the agency has asked for public comment on whether it should establish regulatory definitions for certain terms, and if so, what those definitions should be.
Wine lovers probably won't pay much attention or submit public comments to the TTB. That's the nature of government regulation: As consumers (or “public stakeholders”) we will be affected by whatever comes out of this (even if that simply means more confusing wine labels), but we don't pay attention to the process. The people who will comment will be industry folks who want to use words like Old Vines or Estate on their labels because they think those words impress us – even while they may try to dilute their very meaning.
This is not a Tea Party moment, but wine lovers have reason to care.
-- Dave McIntyre
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