Last week I wrote about the conjunctive labeling laws on the books here in California – and specifically the requirement of placing the parent AVA, Napa Valley next to any sub-AVA of it that is listed on any labels placed on a bottle of wine.
I realized this topic ties directly in with a TTB requirement related to how wineries are tracking those loads of sub Napa Valley AVA grapes. This topic is an issue I have seen often at wineries over the years, and is related to their weigh tags, or more formally known as weighmaster certificates.
Weighmaster certificates are a legally regulated document which track the purchase/sale of a load of wine grapes. (in this example) They are required to have a specific set of text & fields on them, however an appellation field is not one of them. Here is where the TTB rub comes in.
The TTB sees a weigh tag documenting a load of grapes as a “source document” or in other words think of them as birth certificates for your wines. The details that you fill in on a weigh tag tie directly in with what you eventually will or will not qualify to list on the wine label for the wine those grapes become a part of.
Here is an example of what I’ve seen commonly happening on weigh tags. A load of grapes from a sub AVA of Napa Valley comes into a winery. The winery does have an appellation field on their weighmaster certificate template. (Score one point for their compliance!) However when they write up the weigh tag for that load of grapes they fill in the appellation field with “Napa Valley” when they need to list the sub AVA instead. This will mean that come label design time for the wine those grapes are made into it would NOT qualify to list the sub AVA on its label – because it was not documented on the “source document” or weigh tag.
If wineries would first make sure to include an appellation field on their weighmaster certificate template and then next ALWAYS be as narrow as possible in the AVA they list on all their weigh tags this will provide them the widest options come label design time & cover them to any TTB scrutiny.