TTB: time to clear up vague, misleading label terms
Do you ever wonder about the real meaning of certain terms on wine labels? Well, so do a lot of other people, which is why the Federal government is opening up a real can of worms with its announcement that the agency in charge of wine label wording, the Tax and Trade Bureau (TTB), is launching hearings designed to reconsider the definition of such terms as “estate,” “estate bottled,” Proprietor grown,” “Vintner grown,” “Vineyard,” “Single vineyard,” “Old Vine,” “Reserve,” “Barrel Select” and a host of others.
(You can read the Notice of Proposed Rulemaking here. Scroll down to Notice No. 109, which will give you a PDF.)
Big news, and about time. For too long, wineries have had too much leeway in their creative employment of such words, which are confusing and can mislead consumers into coming to conclusions about the wines that aren’t true.
Take the term “estate bottled.” Up until now, a wine can be called “estate bottled” only if (a) it is labeled with an appellation of origin, and (b) the bottling winery is located in the labeled viticultural area, grew all of the grapes used to make the wine on land owned or controlled by the winery within the boundaries of the labeled viticultural area; and crushed the grapes (there are some additional restrictions).
That’s reasonable enough, right? Here’s where things get murky. For years, TTB has (in their words) “allowed the term ‘Estate grown’ to be used as a synonym for ‘Estate bottled,’” meaning use of the former would have to conform to the same conditions that govern use of the latter. But “some industry members” now are requesting TTB to let them use “Estate grown” even if “Estate bottled” conditions haven’t been met, since, they argue, “Estate grown” says nothing about bottling conditions.
That may sound reasonable, too, except that you have to wander further into the thicket to understand just how radical this proposed change is. For it all centers around the definition of “estate.”
The problem, in TTB”s words, is that “the regulations do not address or define the word ‘Estate’ or ‘Estates’…”. In other words, the word “Estate/s” means nothing…nada…zilch…and never has. So even though the word seems to convey some sort of authenticity or quality or prestige sourcing, it doesn’t. It’s about as useful as the words “New!” and “Improved!” on a box of soap flakes (and using it so loosely erodes the confidence the consumer has in wines that really are estate grown). Therefore, if “estate/s” is meaningless, and “estate grown” is divorced from its connection to “estate bottled,” then “estate grown” is meaningless. And down the slippery slope we go.
TTB is asking the public to weigh in on these things. On their website, they present a list of fuzzy label terms, and then they ask:
“1. Which terms currently used in wine labeling and advertising should TTB consider defining, if any, and what should those definitions be?
2. Why or why not should TTB consider defining such terms?”
I’ll take a crack at some of them.
“Reserve” and “Private Reserve.” These are routinely and wantonly abused because they have no meaning whatsoever. A wine cannot be a “reserve” unless there’s a “regular” but in case after case, you find there is no regular. So change the law. Make it mandatory that “reserve” is a small percentage of the winery’s regular bottling of that wine.
“Barrel Select.” A true barrel selection means you took a portion of your best barrels, as determined by tasting, and bottled them separately. Unfortunately, most wines labeled “barrel select” don’t seem to have undergone this sorting out process. Change the law to make “barrel select” mean what it says. (The term “barrel select reserve,” which quite a few wineries use, therefore would be an oxymoron.)
“Old Vines.” Consumers think this is some kind of guarantee, both of age and of quality, but it’s not. It doesn’t mean anything. Change the law to make “old vine/s” mean vines that are at least 25 years old; and then make it so that the labeled wine has to contain at least 90% of grapes from those vines.
“Old Clone.” Nobody knows what this means, either, because it doesn’t mean anything. There are no “old clones,” properly speaking. There are “old selections,” but just because a vine is “old selection” is meaningless from a quality point of view. Therefore, change the law. If a winery says it’s “old clone,” make them spell out just what clone or selection they’re talking about, and make them prove that the vines the wine is made from, or at least 90% of them, indeed are comprised of that selection.
The following terms also are meaningless, but we don’t want the hand of government to get too heavy, do we, so I’d leave them alone: “Proprietors Blend,” “Select Harvest,” “Bottle Aged.”