Wine Labeling Getting Harder and Easier at the Same Time
The TTB, the federal bureau charged with regulating the sale of alcoholic beverages, is considering defining some words often used on wine labels.
The regulators are wondering whether to require strict definitions for an array of terms that include “Proprietors Blend,” “Old Vine,” “Barrel Fermented,” “Reserve,” “Select Harvest,” “Bottle Aged” and “Barrel Select.”
The industry’s reaction to the proposed regulations has been an almost universal, “Aw c’mon. Those are just marketing words. They don’t mean anything.”
Interestingly, their kvetching seems to have prompted a beneficial change in the existing label approval process.
What drives wineries nuts is not so much the labeling regulations themselves. (Regulate “barrel select” all you want, they’re just going to come up with something as impressively meaningless. They’re marketers.) Most frustrating is the drawn-out process labels go through before they can be slapped on a bottle and sold to an unsuspecting public. Labels are submitted, then sit in someone’s inbox for a few weeks or months or however long it takes for that someone to get around to opening their email. After all of that, a significant percentage of labels are rejected for reasons having nothing to do with the label itself. To wit:
TTB has found that applications are often returned to the applicants for correction due to problems with image clarity or distortion, file compression, and resolution issues intrinsic in the submission of some electronic label image files. While the actual printed labels may conform to the TTB requirements, the inadvertent distortions that sometimes appear on the images of those labels through the transmission process cause TTB to return applications for correction, sometimes multiple times, which results in processing delays.
Which can put businesses with wine to sell in the hellish loop familiar to anyone who has ever tried to email a photo to his grandmother, sending and resending the damned image in different resolutions and formats in hopes that one of them might work on her modified Kaypro computer.
So, in order to decrease the impact of bad file compression or out-of-whack monitor color balance on the wine business, the TTB will no longer assess “whether the mandatory information is presented in a manner which complies with all applicable legibility and type size requirements (including characters per inch and contrasting background) specified in the regulations.” Per a regulatory revision announced on April 29, they’re only going to confirm that required content is present on the labels, leaving the art direction to the wineries themselves. We, the wine consuming public, will once again be at risk that deceptive winemakers will use non-contrasting fine print to hide their use of nuclear waste in the fining process.
Anyway, whatever happens to the new regs, this change should streamline the review process and the number revisions wineries are asked to make in their labels. Which is progress.
May 6th, 2011 at 4:49 PM
It sounds like the pre-existing type size and color laws will stay on the books even though the TTB will no longer review each label for compliance; is that correct? I see that the TTB “reserves the right to review and return applications for these reasons when it deems necessary,” which suggests to me that perhaps the TTB will still be keeping an eye on the larger wine brands like Yellow Tail and Franzia. Do you think we will start to see smaller wineries ignore the labeling requirements?
May 6th, 2011 at 6:27 PM
I doubt it, Cody, because it would suck to get caught and have to re-lable a bunch of wine.
I worked in the financial industry for a while, and advertising financial products is highly regulated. The tendency when the regulators stopped worrying about a given regulation was to only enforce really, really egregious abuses. It was one of those you’ve-almost-got-to-be-looking-for-trouble things.
I’m guessing wine is going to work the same way, and that reasonable, good-faith trip-ups will be handled without a fuss and everyone benefits because we’re not wasting a lot of time up front, where no violation exists.
May 7th, 2011 at 2:27 AM
I would love for those terms to be better defined. The whole argument for the “quirky/animal/fun” label plaguing so many wines these days is because traditional (informative) labels are too hard to understand.
Try explaining what an “old vine” wine is. For a long time I thought that old vine led to a distinct characteristic in the wine. And when my customers would approach me asking for something “old vine”, I would give them something that I thought tasted like old vine. Until I realized that those words mean nothing in terms of flavor or style.
Call me naive, but I still believe that wine lovers will eventually go back to reading labels as a way to get information about what may be in the bottle.