Issue link: http://winesandvines.uberflip.com/i/131907
C O M P L I A N C E co u n s elin g by Ann Reynolds, Wine Compliance Alliance Guidance for assessing whether a new label approval is necessary W ine labels are an ever-popular topic in the world of compliance. In my most recent column (see "Decoding wine label language" in the Winter 2013 issue of Practical Winery & Vineyard Journal) I focused on the various items that appear on labels from a Trade & Tax Bureau (TTB) regulatory standpoint. I would like to follow up and cover another common label-related activity that wineries, wine cellars and wine importers encounter in compliance: the process of applying for federal label approval. These approvals are behind that very common acronym used to refer to them in the industry: COLA (certificate of label approval). The label approval or COLA is a required step that comes at either the beginning or the end of a wine's life. The beginning timing applies in the case of wines that are imported into the U.S., while the end timing applies for wines that are bottled in U.S. facilities. Prior to 2002, all label approvals were submitted via snail mail, which involved completing the TTB paper form in duplicate on legal size paper and sending it in to the TTB offices in Washington, D.C., and waiting several weeks (at least) to receive a response. All in all it was a fairly cumbersome and time-consuming process. The TTB has made great strides to address both of these issues for the wine producer and TTB procedures. In mid-2003, TTB released its electronic filing system, COLAs online. This system meant no more paper forms and no more snail mail. The percentage of label approvals they receive via this electronic system is 90% of the total applications. In 2012, the TTB received more than 180,000 label approval submissions. TTB expands list of allowable revisions to approved labels Page three of the original label approval paper form contained a list of changes that could be made to wine labels with previously approved COLAs on file. In July 2012 the TTB announced that it had updated this list of allowable changes. This meant if the changes you made to your label fell within their updated list there would be no need to submit for a new label approval. This expanded list of allowable changes would be a time saver for wineries and TTB specialists tasked with reviewing and approving labels. A few new allowable revisions announced in the July 2012 update Why is Ridge Vineyards adding ingredients to its back labels? S tarting with the 2011 vintage, Ridge other water-based treating materials, Vineyards is listing ingredients may not total more than 1% of the volon its wine labels. The practice is not ume of the treated wine, juice, or both required by the TTB but a choice made wine and juice, from which such wine by the winery. While ingredient labelis produced." ing is not required for wine, wineries Both of the above pieces of informado need to be aware of day-to-day TTB tion—the amount of product added and recordkeeping requirements related to gallons of water used to dilute (if used)— various wine additions. should be recorded in some form of work The current list of materials authoorder document and kept as part of the rized for treatment of juice and wine also required winemaking records. contains the specific amounts allowed A full summary of the list and limitato be added. These include both maxitions to their use can be accessed here: mum pounds per gallon and, for some tinyurl.com/al7r9l8. wines, the maximum residual —Ann Reynolds amounts they leave behind, Ingredients: HandRidge explains such as 2 grams per liter. "We call our approach to Many of these materials harvested, sustainably must be diluted with water grown grapes, naturally winemaking 'pre-industrial,'" says Paul Draper, before they are added to juice occurring indigenous head winemaker for the past or wine. The TTB allows for yeasts and malolactic 44 years at Ridge Vineyards this per the following regula- bacteria, 1.4% water in California's Santa Cruz tion: "Where water is added addition, minimum Mountains. "For fine wine, to facilitate the solution or effective SO2.PD many modern additives and dispersal of a material, the Example of 2011 Paso processing machines limit volume of water added, Robles Zinfandel true quality and do not whether the material is used ingredients label. allow the distinctive charsingly or in combination with 62 p r acti c al w i ne ry & v i ne yard J U NE 20 13 acter of a fine vineyard to determine wine character. "Given that this processing equipment and these additives are not needed in making fine wine, Ridge has opted to voluntarily include an ingredient list on its wine labels beginning with the 2011 vintage. "Besides sustainably grown grapes and their natural yeasts and malolactic bacteria, we list everything added. These are limited to the few non-invasive additions in use for the past 200 years. "We hope to encourage others making fine wine to entrust their customers with their list of ingredients." Making sense of it all Although an ingredient list is not required by the TTB, if a winery chooses to add a list of ingredients to its back label, it must list every ingredient. All Ridge wines make use of the following: •Hand-harvesting of grapes, which allows an initial selection for clean fruit; •Sustainable farming practices that protect the environment, workers and community;