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. YES! 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. False! See my updated blog which explains why the TTB may allow this. 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.