I’ve been keeping track of the daily news stories about the transitions happening for custom crush winery Crushpad. I’m interested from a compliance (surprise!) perspective and what all the ownership changes and potential moving around of wines means for their customers. There is a kind of crazy connect the dots compliance trail happening there that anyone who had or has their wine at Crushpad needs to be aware of.
The primary compliance area of impact I’m talking about is around the labels and label approvals for all of the custom crush client wines.
The first scenario is for any of Crushpad’s clients whose wine had already been bottled and now plan to sell that wine under their own winery business. In the event that they have created a new label (different from the one originally put on the bottles) for the wine, they would have to request the new ownership of Crushpad to file a new label approval for it. (It is always the bottling winery that submits for label approval regardless of who actually holds possession of the wine.)
For the clients whose wine is still in tanks or barrels, they may decide for business purposes to move their wine to another winery to have it bottled. If this is the case their label options will be somewhat impacted. By moving a wine from the site that fermented it to another site to bottle it will mean the loss of one commonly used label term, “produced”.
That term is a TTB defined one and can only be used on wines that at least 75% of the blend was fermented at the winery site that bottled the wine. So for any of Crushpad’s clients that choose to move their wines they’ll need to be aware of this and other potential label detail implications. (such as the use of a vintage, varietal, appellation or vineyard name on their label)
See what I mean about a complicated connect the dots trail?
In my experience, most custom crush clients are not aware of any of these types of details that impact their wines. Really, why would they be?
No matter what it is in any custom crush client’s best interests to know what their options are for their wines, their labels and what it all means if they are planning to sell the wines.
If you are considering starting a new wine business, to make and sell your own wines you can schedule a “Smart Start” call with my office. Sign up for one through our contact page here: https://winecompliancealliance.com/contact-wca/