Issue link: http://winesandvines.uberflip.com/i/946131
March 2018 WINES&VINES 31 VIEWPOINT its labeling and recordkeeping regulations in 27 CFR part 24 to provide that any stan- dard grape wine containing 7% or more alcohol by volume that is covered by a cer- tificate of exemption from label approval may not be labeled with a varietal (grape type) designation, a type designation of varietal significance, a vintage date, or an appellation of origin unless the wine is la- beled in compliance with the standards set forth in the appropriate sections of 27 CFR part 4 for that label." Napa Valley Vintners, a nonprofit associa- tion with 540 members, and Wine Institute, a public policy advocacy association repre- senting more than 1,000 California wineries and affiliated businesses, fully support TTB's efforts to close this COLA exemption loop- hole. Other wine industry associations from well-established wine regions such as the Sonoma County Vintners and Oregon Wine- growers Association as well as from up-and- coming regions such as the Texas High Plains Winegrowers Association also have encour- aged TTB to adopt the proposed Notice 160 amendments. In September 2016, TTB requested addi- tional public input on its proposed amend- ments and specifically called for "comments regarding whether any geographic reference to the source of the grapes could be included on a wine label in a way that would not be misleading with regard to the source of the wine." NVV and Wine Institute put forward a joint proposal that would allow grape source information on COLA-exempt wines while at the same time protecting AVA names as indi- cators of wine origin. A producer of a COLA- exempt wine, for example, would be able to state on the label that the grapes in the wine were grown 100% in Sonoma County, Calif., but the wine could not carry the Sonoma Val- ley AVA if it doesn't meet the Sonoma Valley AVA requirements. Simply stated, no wine can carry an appellation of origin unless it meets the federal requirements for that appellation of origin. AVAs were developed to serve consumers as reliable indicators of wine origin. The pres- ence of an AVA name on a wine label signals to consumers where the grapes were grown and where the wine originates. By closing the COLA exemption loophole, TTB will assure consumers that this is always the case, whether the wine is sold through interstate or intrastate commerce. Richard Mendelson is a wine lawyer at Dickenson, Peat- man & Fogarty and has earned a reputation as one of the preeminent wine lawyers in the United States. He also directs the Program on Wine Law and Policy at UC Berkeley Law. He earned a bachelor's degree from Harvard College, a master's from Oxford University and his law degree from Stanford Law School. Contact ClearWater Tech today for details and Special Pricing! And don't forget to stop by our booth at WiVi. PRESERVE THE INTEGRITY with ClearWater Tech Ozone Solutions • CONVEYORS • DESTEMMERS • CRUSHERS • BARRELS • TRANSFER LINES • WELL WATER TREATMENT • HOSES, CLAMPS • DRAINS, FLOORS, WALLS • FITTINGS • VALVES Winery Applications: Final rinse/surface disinfection of: ClearWater Tech provides plug-and-play, wall-mounted and mobile ozone disinfection solutions for the wine industry. Produce a sustainable and more desirable product by means of: minimizing water consumption, reducing energy costs, and less wear-and tear on processing equipment, while controlling bacteria, molds, and other microbes. ClearWater Tech cold-water rinse systems reduce hot-water and chemical use, without leaving behind off-tastes, odors or residues, preserving the integrity of your wine. GRITY lutions TMENT WALLS and try. means osts, and ontrolling water odors C1 MOBILE CART CIP PANEL-MOUNT PRESERVE THE INTEGRITY wine@cwtozone.com | 800.262.0203 | 805.549.9724 | wine.cwtozone.com VISIT US AT CENTRAL COAST WINE INDUSTRY BOOTH 131 VISIT US AT CENTRAL COAST WINE INDUSTRY BOOTH 131