Category Archives: Wine Labels

Talking wine label compliance with Rob Mondavi
Posted on 2015-04-28 by Ann Reynolds

Winery compliance as a profession is a rare and generally unknown one. Most people I meet have no idea what the term “winery compliance” means. One of the easiest ways to explain what it is that I do is to point to a wine label and state “everything that you see there is regulated by the federal, and potentially state government and wineries are required to maintain records to back them up”. Their faces will light up and they’ll nod their heads with an “I get it” sort of look.

There is a lot going on behind the scenes of a wine label, so as part of my business I have a lot of conversations with clients around the topic. These conversations are most often in the label design stage of planning for a bottling. We talk about the specific details of their wine’s blend breakdown (Vintage, varietal, appellation, etc) and based on what those are then tells us what it will or won’t qualify to list on its labels.

I had one of these conversations recently with client, colleague and friend Rob Mondavi, President of winemaking for Michael Mondavi Family Estate who had a few questions around the use of two common wine label items, AVAs and vineyard names. He would tell me the percents of a wine blend and then ask whether an AVA or vineyard name could be listed on either the wine’s front or back label, or both.

For the first topic of listing an AVA, his question was if a wine blend was sourced from two of Napa Valley’s sub AVAs could they both be listed on the back label? The answer: no. The federal requirements (TTB) for use of an AVA on a wine label require that a minimum of 85% of the grapes used to make the wine blend must come from that AVA. So then the math would never work to list more than one AVA on any wine label. I will point out the “exception” to this is in the case of listing a sub AVA and its parent AVA on either the front or a back label. For example, for a wine with 85% or more of its grapes coming from the Atlas Peak AVA, it could list “Atlas Peak, Napa Valley” on either label. (Note: It would also be required to list both per CA state law – see earlier blog post on this topic)

The next topic we discussed was the use of vineyard names on a wine label. Rob wanted to know about listing more than one vineyard site on a back label. This would be acceptable to the TTB. They would require the vineyard source information to be listed in either of the following formats. Either the vineyard sources would be listed by name in descending order OR each vineyard would be listed by name along with it’s actual percent in the blend. 

This is different from listing a vineyard name on a wine’s front label. In that situation, use of a vineyard name becomes what is known as a “vineyard designate” and then per TTB requirements the wine blend must contain at least 95% of its grapes from that specific vineyard site. 

These are fun and satisfying conversations for me to have with my clients. They exercise my wine label compliance muscles, and at the same time provide bite size pieces of learning for my clients. (The best way to learn winery compliance) Rob was doing his best to stump me during this conversation- and as he put it, “I’d really like to believe that you’re incorrect, but unfortunately realize that more than likely you’re not”. In other words the legal ins and outs of wine label regulations often don’t make sense to the folks being regulated by them, but they’ll play by their rules to maintain that “truth in advertising”.

If you want to know the full story on all federally regulated wine label items, you may be interested in my book, The Inside Story of a Wine Label.

 





AVAs on Wine Labels: Continued
Posted on 2015-03-31 by Ann Reynolds

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.





What do the proposed Paso Robles AVAs mean for your weigh tags right now?
Posted on 2013-09-26 by Ann Reynolds

AVA

I see that 11 new petitions have recently been submitted to the TTB for new AVAs all within the current Paso Robles AVA. For one, that’s a lot of slicing and dicing all at once! And of course there has already been plenty of history to the quest to create several more sub-AVAs within the sizeable piece of land that the parent AVA Paso Robles already is. (5th largest in California)

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5 Gallon Kegs, Label Approvals and You.
Posted on 2013-04-12 by Ann Reynolds

5 gallon kegs have become a popular way for wineries to get their product out into the marketplace, specifically the by-the-glass marketplace. I had a client contact me recently for assistance with a new label approval (COLA) for his upcoming bottling. I’ve filed these for him in the past but this year was the first time he’d decided to try out the 5 gallon keg route. He asked me if a label approval was required for them, and I honestly didn’t have an answer for him right away.

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TTB Label Approval Search Advice From Eliot Ness
Posted on 2012-06-28 by Ann Reynolds

The TTB’s website really does have a lot of good information. (If you know where to look) I myself can vouch for this firsthand as I’ve been viewing it as part of my profession since 1998. It has come a long way since then! Now they are going back to their roots by including a section titled, “Eliot Knows” which is basically a version of their FAQs page.

Eliot’s latest information for the curious wine regulation searcher is about one of the TTB’s sites, the Public COLA Registry.

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Teaching An Old Wine a New AVA.
Posted on 2012-04-11 by Ann Reynolds

A recent discussion came up on Facebook around the use of newly created AVAs (American Viticultural Areas) on wine labels made from vintages pre the AVA’s existence. The discussion was around the recently created AVA of Coombsville in eastern Napa. The question that came up was would that be allowable under the TTB’s labeling regulations? i.e. If you are about to bottle a 2009 wine and wanted to put Coombsville (which became an AVA in December 2011) as an AVA on the label could you do this?

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Does Your Wine Have an Outdated Identity?
Posted on 2012-04-04 by Ann Reynolds

Did you know that all wines have a standard of identity? All US wines that is, and this is in relation to how the TTB (www.ttb.gov/wine) defines them. A required item for any wine label is what the TTB refers to as a “class & type”. In most of our cases the class we are speaking of is the “grape wine” class. (Some of the others include citrus, fruit and sparkling just FYI) Then moving into the “class” part of it the list of options there used to include 17 designations of European origin. An agreement was signed between the US and the EU in 2006 which essentially removed those 17 designations for use on US wine labels unless you’d grandfathered their use in via earlier labels.

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For Whom The Label Approval Responsibility Tolls.
Posted on 2011-12-20 by Ann Reynolds

Back on the ever popular topic of wine labels, I’ve got a question for all of you involved in the label approval part of the process. Say a wine is made at winery A but then shipped to winery B to be bottled. Which winery is responsible for obtaining the TTB label approval for it?

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How to Create the Perfect Blend When Designing Your Wine Labels.
Posted on 2011-12-01 by Ann Reynolds

The practice of winemaking is often referred to as an art or a craft. The process of creating a label is a very intricate one as well. It is intricate not only because of the TTB regulations that surround them but also because of the many parties that are involved in their design. From winery to winery that list of involved players does vary which has a direct correlation with how efficiently (Or not!) labels are planned for.

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OK Wineries………….Everybody Concentrate!
Posted on 2011-11-20 by Ann Reynolds

This is a cautionary post for all the wineries that as a result of the low sugar levels in their fruit this year due to the lack of a summer decided to boost the sugar level of their batches of juice and must by adding grape concentrate. Beware that come bottling time for any of those finished wines that had concentrate added to them they will not be eligible for “Estate Bottled” on their label.

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