Not included in the article: The TTB says there is a “clear sliding scale for dealing with any label inaccuracies.” They tell me that “an investigation would allow us to determine whether a winemaker made an honest mistake or had an intent to deceive. There’s a big difference, and we wouldn’t treat them the same way.”
And I asked, “If a winemaker puts 100% on the label, does that invite an investigation from the TTB?” The answer: “No. There would have to be some other specific reason.”
First off, there isn’t one regulatory body that we wineries have to deal with but 51. How many state ABC agencies did you check with to see how such labeling would be addressed? There are many cases where the TTB has approved labels but states have rejected them. The Rex Goliath labels were all TTB approved but rejected in Alabama. Dry Creek had a label rejected in Florida but approved by the TTB.
Also, because one TTB agent says something doesn’t make something true if its not encoded law. Three vintages ago we were told by the TTB we had to put the words “white wine” on our Blanc de Pinot Noir label because pinot noir is a red grape. This year we were told we had to take the words “white wine” off the Blanc de Pinot Noir label because pinot noir is a red grape. So forgive me if I don’t take what was written as gospel.
First, let me make clear that I’m not in the position of a winemaker or winery owner, dealing with mind-numbing bureacratic silliness. I don’t envy the position.
But let me also say that you can cherry-pick examples to suit your argument, but it appears that you are assuming the worst will always happen with regards to label change, so a move toward more specificity is futile. I’m curious to know if there’s reason to believe that California would thwart such efforts. Or Oregon.
The Alabama case is a ridiculous outlier and not related to this discussion, in my view. But I understand the annoyance that the Florida case must generate.
It’s certainly true that some wines sold as Pinot Noir have been blended with wine from other grapes. But we still don’t have many (any?) examples from the premium part of the market. But I’m a little puzzled that you seem to have made this “100% Pinot Noir” such an issue and seem to imply that if wineries don’t do it, they must be hiding something. By analogy, it’s also true that some journalists have been caught fabricating sources. Does your news program air with the statement “100% true”? And what can we conclude if it doesn’t?
Whoa, Al, now you’re putting words in my mouth. That’s not my position. At all.
What I’m trying to explore is this: Can more specific labeling be accomplished without changing existing law? There’s debate about whether the answer is yes. The TTB is saying, essentially, “Sure, why not?” But winemakers understandably have issues with trusting the TTB.
I do have one position in this discussion: I think current labeling often confuses the consumer instead of educating them. The TTB claims to want the labels to accurately reflect what’s in the bottle. But most consumers have no idea that a wine labeled Pinot Noir can be 25% non-Pinot. So is that really educating them, or is it obfuscating?
This is not the fault of winemakers. I’m not accusing Adam of hiding something, nor would I. I’m simply trying to understand why, if the TTB says it’s cool, winemakers would still choose not to do it. And it turns out there are many reasons, some obvious, some less so. When they choose not to, it’s not because they’re hiding something. But given the TTB statements, should they reevaluate their position?
I’ve already heard from two winemakers this morning who tell me the TTB’s comments give a green light for more specific labeling. Adam disagrees. I think it’s a good discussion to have, but damned if I’m going to think less of Adam or imply he’s hiding anything. He’s earned much more than that from me and all of us.
By the way, I understand your analogy, but it’s not a good one. Our news reporting is assumed to be presented as 100% “true.” If the public finds out that 25% is fabricated, it’s over. We’re done. We shut down the next day. So it’s not the same thing here.
This subject always makes for good discussions . . . but unfortunately they don’t lead anywhere. Winemakers do not HAVE to be completely honest in what they do to go from grape to bottle, and because of this, there very well may be suspicion that continues to last for a long time. What can winemakers do to dispel this? From my perspective, they don’t have to do anything - except be transparent in what they do. That said, a lot can be gained from the winemaker’s side by NOT divulging - for the assumption will be that a small boutique producer will do things in a more ‘artisinal’ way compared to a larger producer. Is this always true? Of COURSE it isn’t - but that’s the myth, mystique, and ‘conventional wisdom’ that continues to be upheld in our industry . . .
But why pick on a grape that shows adulteration so readily? Grapes like Cabernet Sauvignon and Merlot often need blending to make a better wine. Many of those producers max out on the blending to make the best wine, while complying with the varietal labeling for marketing purposes, while knowing what is truly the best wine would be under 75% and thus, harder to sell.
Sorry, Evan. I mistook you for one of the people who was pushing the 100% PN label in the similar thread you recently started, so I thought it was a crusade for you. And it’s true that analogies are rarely perfect because, otherwise, why would an analogy be potentially useful. But, setting the legalities aside, both situations are really about trust.
As far as the legalities, as Wes has implied I think the 75% rule in California was mostly motivated by Cabernet / Bordeaux blends. Not sure, but I think even Oregon allows 75% for Cabernet Sauvignon? But at either 75% or 90%, I don’t think these limits have much effect on premium Pinot Noir. I know a lot of Pinot producers, and have helped a few of them. I don’t think any of them are blending syrah into their Pinot (the ones I’ve helped are not). It doesn’t make much sense to me except at the low end at high crop levels, or with wineries that don’t understand Pinot. As I mentioned in the earlier thread, I think the situation was different in the 1960’s and 1970’s, when I think it was common for the Pinots to be blended.
For the most part, I share your optimism. Comments like those from Rick Moshin are a little troubling, but that seems much more exception than rule. If I have any sort of agenda, it’s about advancing the conversation on consumer education. I’m not a big fan of labeling laws to begin with.
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