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.