Issue link: http://winesandvines.uberflip.com/i/131907
C O M P L IAN C E surprised many of us who have dealt directly with TTB compliance over the years. They were surprising because they are all areas that the TTB had previously indicated were distinctive differences in a wine's details, hence their requirement for a new label approval. Three examples of new allowable changes to label approvals Alcohol content: Prior to the TTB's allowable revision updates, if you had an existing label approval for a wine with an alcohol level in the table wine tax class (alcohol content between 7% and 14%), and in the next year the wine for that bot- ABC Winery ABC Winery 2012 Rosé Wine 2013 Rosé Wine 13.5% Alc. by Vol. 14.5% Alc. by Vol. Left: Example of previously approved label. Right: New label with allowable alcohol content change in a different tax class. •Indigenous yeasts brought to bird- and wind-damaged mature berries by bees and wasps; •Naturally occurring malolactic bacteria on the grapes in the vineyard (most fruits contain malic acid, and where that is present so is malolactic bacteria). The bacteria comes in with the grapes and is found in the fermentors immediately after crush; •Oak from barrel aging; •Minimum effective addition of SO2 needed to consistently show the distinctive character of a fine vineyard in the wine. Other additions used when required Water: When temperatures during a Zinfandel harvest rise significantly, this variety can over-ripen quickly before there is opportunity to pick all the blocks. If that occurs, we make a small addition of water to those fermentors to rehydrate grapes that lost water to the vine in protecting it from excessive heat. Egg whites: The most gentle of all fining agents, fresh egg whites have been used for at least 200 years to clarify fine wine and/or moderate tannins. For example, virtually every Bordeaux from tling had an alcohol level of 14.7%, which is a separate tax class, you were required to change the alcohol content on your label and submit another label approval to cover that wine. Now the TTB has made this an allowable change. Keep in mind that the class and type must remain the same as what was listed on the previously approved label. The class and type is a required wine label item, and varietal names are the most common example of these. Change in the optional "produced by" or "made by" statement: These phrases are optional terms that can be used in the required name and address statement on your wine label. It typically appears on the back label. If you use either of the terms "produced" or "made," they have the same TTB-defined definition. At least 75% of the wine must have completed fermentation at the site where the wine is bottled. The TTB updated its allowable revisions for this item, now allowing wineries to change "produced" or "made" to one of the other optional statements (such as vinted, cellared or blended). This only applies to changing your labels from "produced" or "made" to the other the First Growths to the region's lesser wines have been fined with five or six fresh egg whites per barrel in most years for at least 100 years. For Ridge Vineyards, clarity is never an issue, but egg white fining can moderate the texture of the tannins in the few parcels of Cabernet or Merlot that, in a particular vintage, might show excess tannin. The egg whites precipitate and the wine is racked off and filtered, leaving no trace of the egg white behind. Calcium carbonate: If natural acidity is excessively high in a few parcels of the Monte Bello or Geyservillle vineyards, a small addition is made during active fermentation to achieve balance by precipitating a limited amount of acidity. Tartaric acid: Acidity in Zinfandel (Geyserville being an exception) is, on occasion, not as high as would be ideal but still better than Syrah. To achieve balance in those parcels, small amounts of tartaric acid, the natural acid in wine, are added. Draper feels strongly that ingredient labeling should not be a legal requirement for wine. The more than 60 additives approved for use in wine in the United States and in the world's major wine-producing countries are all safe for optional statements. In other words, if you decide to change a previously approved label from "cellared and bottled by" to "produced and bottled by," then you need to submit for a new label approval. Produced and bottled Cellared and bottled by ABC Winery by ABC Winery Somewhere, Calif. Somewhere, Calif. Left: Example of previously approved label. Right: New label with allowable optional statement change. Changes in use of vintage date: Prior to this update in allowable revisions, the TTB did not require wineries to submit a new label approval if the only thing different was the vintage. Now, with this update, the TTB is also allowing addition or deletion of a vintage on a label as well as simply updating it from the previous year. If a previously approved label either did or did not list a vintage, and consumption. "There are no health risks to the consumer," says Draper. "However, unlike virtually any other food product, the fact that each wine in each vintage is handled differently using different additives given the makeup of grapes that year's weather has provided, makes it impractical to apply ingredient labeling to wine. Just requiring calories per serving, let alone ingredients, would be an untenable practical and financial burden for small and medium size producers. "The federal authorities, however, do permit a wine producer to voluntarily provide, on the label, the ingredients involved if all additives are included. Listing the naturally present ingredients and few non-invasive additives necessary to making fine wine would be something fine wine producers might consider. It would set their wines apart, for example from natural wines that do not use the minimum effective SO2 necessary to consistently show the natural character of a fine vineyard in a wine and from wines that do not attempt to show a sense of place. This could provide a definition of what is fine wine." —Ridge Vineyards pr actica l win ery & vin eya rd JU NE 20 13 63