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An All-American Appellation

April 2009
by Jim Gordon
This month's column revisits a topic I first addressed here in March 2007. Then just a discussion of truth in labeling, now it has evolved into a concrete proposal that would rectify a very poorly conceived section of the federal rules on wine labeling. An interstate coalition of winegrape grower groups has now petitioned the Alcohol and Tobacco Tax & Trade Bureau (TTB) to revise the rules. We hope that petition will be accepted and opened for industry comments later this year.

Let's get into the topic via a multiple choice quiz. As a thin barrier to cheating, we have listed the answers upside down at the bottom of the page.

1. What minimum percentage of wine grown within their borders do all the following countries -- Argentina, France, Germany, Greece, Italy, Portugal, Spain -- require in wines labeled with their country name as the appellation of origin?

A. 100%

B. 95%

C. 85%

D. 75%

2. What minimum percentage of American wine is required in a wine labeled as American?

A. 100%

B. 95%

C. 85%

D. 75%

3. Which of the following agricultural products must consist entirely of materials grown and processed in the United States to be labeled as "Product of USA," "Produce of the USA" or "Grown in the USA"?

A. Hamburger

B. Pecans

C. Grapes

D. All of the above

Should the wine labeling laws be changed so that wine packages labeled "American" contain only U.S.-grown wine components?

This is one of those "duh" questions that should hardly require any discussion. Of course a 100% requirement on American appellation wines is a good idea. It's hard to believe that a country-of-origin requirement like this is not already mandated in the U.S., as it is in most of the world's other great wine-producing countries, and as it is for all U.S.-grown perishable agricultural commodities, including fresh grapes.

That's not to say that the current 75% rule doesn't serve real needs for a few defenders. I suppose that internationally minded wine companies can increase their profit margins in some years by blending cheaper juice from Chile or the south of France into their "American" wines. Occasionally Eastern U.S. Riesling producers have bought Canadian Riesling as a more logical blender from a style viewpoint than Washington or California Riesling. The majority of wineries that use "American" on their labels, however, do so because they are blending together wines from different states. A 100% American label would suit them fine.

In the long run a consumer's need for labels that tell the whole truth, and the American grapegrower's need for respect and reasonable prices clearly outweigh the needs of a few wineries for insurance or enhanced bottom lines. Four statewide grower organizations recognized this and banded together to request changes in the TTB's labeling regulation, 27 C.F. R., part 425. Signers of the petition, which originated in California, are the California Association of Winegrape Growers, the New York State Wine Grape Growers, the Oregon Winegrowers Association and the Washington Association of Wine Grape Growers.

Their petition calls for a change from the currently lax 75% rule to 100% for wines labeled with country of origin. It also would change the little-known allowance of 15% foreign wine in wines labeled with specific American Viticultural Areas to 0% foreign wine. Wines that continue to blend American and foreign sources would be labeled with the exact percentage of wine by volume from each country.

We think the petition is good for the great majority in the wine industry. Who wants consumers to discover that the "American" Merlot they bought may contain 25% of Bulgarian wine, or that a bottle of "Paso Robles" Syrah could be 15% South African?

It's time to plug the foreign-blending loophole and make American wines all-American. As I argued in that first column two years ago, the American wine industry will benefit in the long run from making its products even better, and by making the sources of those products even more transparent.

The correct answers are: 1) 100% 2) 75% 3) All of the above.
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