Ingredient Labeling: A Winemaker Strikes Back – Wine-Searcher

When I go the grocery store, I check the labels on all the foods I purchase.

Over the past year, due entirely to a friend with celiac disease I moved to a gluten-free diet. For her, this was truly a matter of health; for me, it was simply an attempt to be supportive. I discovered that, not only did I enjoy eating sans gluten, but I felt better, and it has been an integral part in a 60-pound weight loss. I am gluten-free going forward with no plans on reverting to my gluten-ous ways.

As I mentioned, reading ingredient labels on foods is now incredibly important to me. So is the GF Scanner app on my phone, as with some items it isn’t truly clear whether they contain ingredients with gluten. As a person now fully committed to this level of caring as to what I put into my body, you would think that I would agree entirely with W. Blake Gray’s recent opinion piece on wine ingredient labeling. And yet, as a producer of fine wine, I cannot agree with him. There are several reasons.

In his article, Blake compares wine to food: “beans, hot sauce, frozen seafood dumplings, crackers”. But wine, in the United States, isn’t treated the same as food. With food, labeling requirements are set by the federal government. The FDA establishes and enforces the accuracy of ingredient, nutritional, and volume labeling and that is the one standard a label must adhere to.

Wine doesn’t have that one standard. Yes, labels are reviewed by the Federal Government, not only for accuracy but also for undefined standards. Witness the famous 1975 Kenwood Artist Series Cabernet Sauvignon, which was rejected as being indecent for David Lance Goines’ painting Reclining Nude in Vineyard on the front of the bottle. There are several other examples where wine labels have been examined in such a manner while food labels are not.

Additionally, when Prohibition was repealed, the control of alcoholic beverages fell to the states as well. Thus, many states have different labeling requirements. Once, at a winery I formerly owned, one of our labels was approved by a state inspector while another (exactly the same except for the Appellation of Origin) label was rejected by a different inspector in the same state – all because of what could be seen as a topless woman on the label.

Different products, different rules

While the EU and foods in the United States have one set standard they must adhere to, wineries have potentially 50 different standards. Of course, state governments often use these standards to raise revenue. A good example of this is Connecticut where each label must be approved by the state at a cost of $200 per label. So, if a wine one year requires a tartaric acid addition that label will be different than the year before and there goes another $200 to the state of Connecticut. Obviously, larger wineries can spread these expenses over many cases shipped to Connecticut. Smaller wineries, however, cannot do so without doing severe damage to their bottom line. The artisanal producers that Blake says that he would most like to support are the ones hurt most by his proposal.

He also mentions that larger wineries are the ones most opposed to ingredient labeling but, if food shows us anything, it is that smaller wineries that would be the ones most hurt. The CFRs (Code of Federal Regulations) for the production of, say orange juice, are so onerous that virtually all orange juice sold in the US is controlled by a few large companies, who can make their product via a formula that is the same year after year. There are not many successful small orange juice companies or grape juice companies, but there are thousands of successful smaller wineries. Blake’s proposal would make it so that the wine business would mirror the food business. Smaller wineries, who adjust their winemaking to adapt to the unique vintage conditions would be disincentivized to do so. Labels must be printed months ahead of time and if a smaller winery decides afterwards that the wine would be better with an acid addition they couldn’t do so without being in violation of the law. The FDA realizes how burdensome their labeling requirements are on smaller producers and exempts them from labeling requirements.

Then, of course, there are the very real issues with additions to wine and how (or if) they should be listed as they aren’t ingredients. Let’s go over a few of the items that Blake mentions:

• Seemingly, water should be listed as an ingredient as most wines are approximately 86 percent water. That would be the first ingredient, you would think. But no, Blake would only have water listed if the item listed was added to the wine, not if it existed in the wine. A 16 percent alcohol wine with less water in it might have water listed as an ingredient while a 13 percent alcohol wine with more water in it wouldn’t have water listed. Which leads us to…
• Per Blake’s argument, sugar would be listed it if was added. But added sugar ferments into alcohol and doesn’t remain in the wine. Therefore, dry wines would have “sugar” listed as an ingredient, but a wine that naturally has sugar remaining in it wouldn’t have to have sugar listed.
• Which leads to the great bête noire of the ingredient movement – Velcorin. Velcorin is the trade name for dimethyldicarbonate (DMDC), a microbial agent that kills yeast, bacteria, and molds in wine and in other drinks. Velcorin, if ingested directly is toxic, but after a few hours it breaks down into other purportedly harmless substances (I say purportedly as I don’t use it, but have read much about it). That breakdown of Velcorin is why you never see it listed on bottles of sport drinks, or teas, or juices – because the FDA requirements for an ingredient list require a manufacturer to list only what is actually an ingredient in a product. Velcorin doesn’t exist as an ingredient in a product after a few hours so even though it is added to those items, it isn’t listed. In this case, Blake doesn’t want wine to be treated the same as food, but to be held to a higher standard than the food labels he looks at.

Through the looking-glass

What of Ridge Winery, which Blake singles out as “an extremely honest California winery, lists ingredients on its labels and lets consumers decide?” Unfortunately, Ridge lists items as ingredients that aren’t in their wines. They list “indigenous yeasts and naturally occurring malolactic bacteria”. But what Blake, and Ridge, fails to mention on the label is that their wine is filtered (Ridge mentions it on their website). What exactly is filtered out? Amongst other things “indigenous yeasts and naturally occurring … bacteria”. So, Blake sets as his prime example a winery where their ingredient list includes items that are neither added to nor exist in their wines. Surely, we are through the looking-glass now.

So, where does this leave me as both someone who is extremely concerned about ingredients in what I consume, but also fully recognizes how government-imposed ingredient labeling would devastate small producers?

I do have a modest proposal that I think could bridge the gap. I mentioned that I use my GF Scanner Ap liberally. Scanning a wine label these days is extremely easy to do. So is scanning a UPC code should a wine have one or a QR code. Have those lead to a winery’s website where they list ingredients, additives (what Blake really wants to know in most cases), and processes. These websites can be updated after the wine is bottled (and long after labels are printed) and aren’t reviewed by state authorities, thus not costing smaller wineries additional dollars.

Moreover, wineries there can use up as much space as they see fit to accurately reflect the care and concern they put into making their wines and tell you fully not only what they are doing but why they are doing it.