When you look at a wine label, do you get
perplexed by terms such as Proprietor’s Reserve or Barrel Select? What
do those barrels select, precisely? How old do vines need to be before
they become ‚€œOld Vines‚€? (That’s a touchy subject in some
demographics!) Does the word ‚€œEstate‚€ mean anything to you, aside
from estate planning?
You’re not alone if you wonder about these things. The Treasury Department’s Alcohol and Tobacco Tax and Trade Bureau (TTB), the successor to the old Bureau of Alcohol, Tobacco and Firearms (ATF) wants to know, too. In a Federal Register
notice published early this month, the TTB asked for public comment on
whether it should amend its regulations to give precise meaning to these
and other terms. The notice is worth reading, and as far as Federal
Register literature goes, it’s a spell-binder.
There is some reading between the lines
to do, however. For example, the TTB notes that industry petitioners
have asked the agency to distinguish between ‚€œestate bottled‚€ and
‚€œestate grown.‚€ The first term is enshrined in TTB regs to mean that
the wine is grown in vineyards owned or controlled by the winery in a
designated American Viticultural Area, and that the winery controls all
aspects of the vinification from fermentation through bottling, on the
premises. TTB policy ‚€“ but not regulation ‚€“ has held that ‚€œestate
grown‚€ should mean the same thing, so consumers don’t get confused.
The proposed change would allow a wine that does not meet the current
standard for ‚€œestate bottled‚€ to be labeled as ‚€œestate grown.‚€
What’s the difference? It could be
something as simple as whether a small winery that owns its vineyard and
uses only its own fruit also owns a bottling line ‚€“ or uses a
contractor to bottle, therefore saving money but losing the ‚€œestate‚€
label. Or it could allow a winery that controls the process from start
to finish but is not in an established AVA to call its wine ‚€œestate
grown.‚€ Boxwood Winery near Middleburg, for example, does not meet the
‚€œestate bottled‚€ criteria because it is not located in one of
Virginia’s six established AVAs. Yet the winery uses only grapes grown
on its estate, and controls the vinification and bottling. For all
intents and purposes, its wines are what discerning consumers think of
when they see the word ‚€œestate‚€ on the label.
On the other hand, if TTB is not careful,
it could allow ‚€œestate grown‚€ to mean anything, and thus nothing.
The agency notes that it already allows the use of the words
‚€œestate‚€ and ‚€œestates‚€ on wine lables without the need to
satisfy the criteria for ‚€œestate bottled‚€ – it is asking whether it
should specify definitions of those words as well.
In general, I favor clarity and
specificity in wine labeling terms, as an aid to the consumer in sorting
through all the marketing hype. So does the TTB. That’s why the agency
has asked for public comment on whether it should establish regulatory
definitions for certain terms, and if so, what those definitions should
Wine lovers probably won’t pay much
attention or submit public comments to the TTB. That’s the nature of
government regulation ‚€“ as consumers (or ‚€œpublic stakeholders‚€) we
will be affected by whatever comes out of this (even if that simply
means more confusing wine labels), but we don’t pay attention to the
process. The people who will comment will be industry folks who want to
use words like Old Vines or Estate on their labels because they think
those words impress us ‚€“ even while they may try to dilute their very
This is not a Tea Party moment, but wine lovers should read the Federal Register once in awhile.
This item was published Nov. 19 on The Washington Post’s All We Can Eat blog.