Federal labeling policies for wines that are made with organic grapes are changing to provide clearer disclosure to the consumer. Wine Industry Insight reports that a Memorandum of Understanding has been drawn up between the Agricultural Marketing Service (AMS) of the United States Department of Agriculture (USDA) and the Alcohol and Tobacco Tax and Trade Bureau (TTB). The TTB will implement the new organic grape labeling policy on behalf of the AMS/USDA.
Labels for Wine Containing Organic and Non-Organic Grapes
Wine labeled with a “Made with Organic Ingredients” statement, and which contains organic and non-organic grapes, must indicate the presence of non-organic grapes in the “Made with Organic…” statement on the label. The following variations to this statement are acceptable:
“Made with Organic and Non-Organic Grapes”;
“Made with Organic [variety] Grapes and Non-Organic [variety] Grapes”;
“Made with _% Organic Grapes and _% Grapes”;
“Made with _% Organic [variety] Grapes and _% Non-Organic [variety] Grapes”
In addition, wines restricted to an “Organic Ingredients” statement must indicate the presence of any non-organic grapes in the “Organic Ingredients” Statement. An example of such a statement is “Ingredients: Organic Merlot grapes, Cabernet Sauvignon grapes, tartaric acid.” Such a wine will also have to bear a Percentage statement (see below).
Percentage Statements for Wine Restricted to an “Organic Ingredients” Statement
When a wine is restricted to an “Organic Ingredients” statement and contains non-organic ingredients such as in the example above, a Percentage Statement such as “55% Organic Ingredients” must also be present on the label. The Percentage Statement must appear on the information panel in proximity to the “Organic Ingredients” Statement. If a wine bears an “Organic Ingredients” Statement in which no disclosure of non-organic ingredients is made, such as “Ingredients: Organic Grapes,” then 100% of the ingredients in such wine must be organic.
Policy Not Entirely Clear
However, when 100% of the ingredients are organic on a wine restricted to an “Organic Ingredients” statement, a Percentage Statement is prohibited in order to avoid consumer confusion with products meeting the “100% Organic Wine” standard. In other words, just because a bottle of wine contains 100% organic grapes, it does mean that it meets the USDA’s standard to be certified organic. For example, if the wine contains added sulfites, it cannot be certified organic. If the winery has not gone through the USDA certification process, it cannot be certified organic.
To avoid confusion, if a wine is made with 100% organic ingredients, it cannot be labeled “100% organic ingredients.” The concern is that consumers might think it is certified. Instead, the wine may label itself with something like “Ingredients: Organic Grapes.” This is supposed to let consumers know that there are no non-organic grapes in the wine.
The new labeling practices went into effect on June 2, 2009.