How to Read
a Wine Label
by Jim LaMar

The label on a bottle of wine undergoes more regulatory and creative scrutiny than perhaps any label on any other commodity. After a design is created and selected, the label must pass muster from the government agency that controls wine production as well as the various government agencies controlling importation and sale in every country where the wine is distributed.

There are collectors of wine labels who don't consume wine and consumers of wine who base their purchases entirely on the appeal of the labels. Understanding wine labels can be difficult and intimidating for the consumer who is primarily interested in the taste of the contents. Knowing what information labels are permitted to and are required to provide can help.

Surprisingly, very little of the information on the label tells how the product in the bottle may be expected to taste. In fact, descriptions which often appear on back labels are completely unregulated and frequently are composed of "buzz words" that appeal to the public palate, rather than being actual notes based on an unbiased tasting of the contents.

The consumer can make better buying decisions by initially knowing the basic facts required on wine labels, subsequently absorbing the idea of what aromas and flavors to expect from regional wine characteristics, and finally considering how this information combines to reveal the tastes beneath the cork. The place to start is with the requirements.

LEGAL ENTANGLEMENTS

Local laws dictate label information for the point of sale where the wine is marketed, rather than where the wine is made. There can be great variation in labeling requirements from country to country. America, for instance, uniquely requires the 1Government Warning on wine labels, so wines from outside the U.S. may either have labels printed especially for exporting to the American market or may have "strip labels" glued on each bottle with the necessary information. Conversely, U.S. wines that are exported to Europe may sometimes be required to cover up or obliterate the alcohol warning statement (which many worldly wine drinkers think is ludicrous, anyway, and prompts them to question the general American mental capacity).

Label information on wine sold in the United States is regulated within a division of the Department of the Treasury. The Alcohol and Tobacco Tax and Trade Bureau (TTB) is responsible for regulation and taxation of alcohol and tobacco2. In addition to issuing federal permits for building wineries, establishing American Viticultural Areas, and overseeing health statements on wine bottles, the TTB approves wine labels. The minimum information required for bottles to be sold in the U.S. (whether foreign or domestic) includes five categories:

WINE LABEL REQUIREMENTS

An identifying brand name is required on all wine bottles. A person's name, such as the name of the owner, may be used as a brand. No name may be used that is misleading or creates and inference as to the age, origin, or characteristics of the product. On wines of domestic origin, no brand or trade names of foreign origin may be used.

It is mandatory that all wine labels identify the contents as being one of several classes. The most common type of wine is Class 1: Table Wine, defined as having an alcohol content of not less than 7% and not in excess of 14% by volume. Other acceptable designations for this same class are "light wine," "red table wine," "light white wine," "sweet table wine," etc. The official TTB regulations tediously and precisely define each class. The following chart summarizes the basics:

An additional distinctive or fanciful proprietary identifying name is permitted in accordance with common trade practice. If a varietal or type with varietal significance (such as "Meritage") is used, if a generic term is used, if the name is qualified with the word "brand," or if the wine is labeled with the year the grapes were harvested (vintage dated), an appellation of origin is mandatory, disclosing the true place of origin of the wine.

Alcohol content must be stated on any wines containing more than 14% alcohol by volume. These wines, even if the level of alcohol is reached naturally, are considered "fortified" and taxed a a rate four times higher than wines under 14%. For wines under 14%, either the alcohol content may be stated or the designations "Table Wine" or "Light Wine" may be used, both phrases implying alcohol content within a range of 7% to 14%.

A latitude of 1% over or under the stated level is permitted on wines above 14%. A greater latitude of 1.5% is allowed on wines under 14% (although in no case is it allowed to exceed 14%). Many wines are labeled "alcohol 12.5% by volume" to take full advantage of this tolerance. The variation is permitted for two reasons: evaporation during aging is not entirely controllable and the common method of measuring alcohol content, using an Ebulliometer, was not entirely accurate. Modern wineries frequently have fairly sophisticated chemistry labs on-site and are able take more precise measurements using a gas chromatograph.

The name and address of the bottler must appear on the label of all American wines, immediately preceded by the words "bottled by."

If the bottler also made at least 75% of the wine by fermenting the must and clarifying the resulting wine, the terms "produced and bottled by" may be used.

"Made and bottled by" may be used either if the named winery fermented and clarified a minimum of 10% of the wine, if the named winery changed the class of the wine (see #2) by adding alcohol, brandy, or carbonation, or if the named winery produced sparkling wine by secondary fermentation.

"Cellared," "Vinted," or "Prepared" means the named winery subjected the wine to cellar treatment, that are specified in the regulations, such as clarification or barrel aging, at that location. "Blended and bottled by" means that the named winery mixed the wine with other wine of the same class and type at that location.

The wine industry was mandated by the U.S. Congress in 1977 to use metric size bottles as the industry standard. As a result, we no longer use the terms 'pint', 'fifth', 'half-gallon' or 'gallon'. For tax purposes, however, all wineries are required to report production in gallons, not liters.

The net volume of the contents can take the form of either the authorized metric standard of fill prescribed in the regulations or non-standard. If the metric standards of fill are used, the equivalent U.S. measurement in fluid ounces may also appear as follows: 3 liters (101 fl. oz.); 1.5 liters (50.7 fl. oz.); 1 liter (33.8 fl. oz.); 750 ml (25.4 fl. oz.); 500 ml (16.9 fl. oz.); 375 ml (12.7 fl. oz.); 187 ml (6.3 fl. oz.); 100 ml (3.4 fl. oz.); and 50 ml (1.7 fl. oz.). For sizes larger than 3 liters, the containers must be filled and labeled in quantities of even liters (4 liters, 5 liters, 6 liters, etc.).

The net contents need not be stated on any label if "blown, etched, sandblasted, marked by underglaze coloring, or otherwise permanently marked by any method approved by the Director, in the sides, front, or back of the bottle, in letters and figures so as to be plainly legible under ordinary circumstances." The net contents statement also must not be obscured in any manner, such as being covered, even partially, by an applied label.

If the measurement of the net contents is non-standard, the net contents statement must appear on a label affixed to the front of the bottle.

For tax purposes and to satisfy Truth in Labeling laws, any size designation on a bottle must be filled to within 1% of that size. The TTB has the right to pull samples off the bottling line to insure uniform fill levels. If the fill is too low, the winery could conceivably bottle an extra bottle or two. However, if the fill level is too high, the winery would be under-reporting the number of (usually 2.4 gallon) cases bottled, thereby paying less Federal tax.

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VINTAGE DATING

A vintage year may be used on labels of wine that is 95% derived from grapes harvested and fermented within that calendar year and which is labeled with an appellation more specific than a country name. The requirement doesn't call for 100% in order to allow for the producer to use newer wine to "top" barrels from which evaporation occurs over the period of months or years as the wine ages.
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FURTHER LEGAL ENTANGLEMENTS

DECLARATION OF SULFITES

Any wine bottled after July 9, 1987, must have a label affixed that is a declaration of sulfites. The label may be either front, back, strip, or neck, but it must be on every bottle.

Sulfur (or sulphur) is a non-metallic element that is one of the most common present in nature. It is used to maintain the stability and potency of some medications, also in the production of gunpowder, matches, fertilizers and fumigants, to vulcanize rubber, and as a part of common compounds used to preserve a wide variety of foods and food products, including to prevent melanosis ("black spot") on shrimp and lobster, to "condition" dough, to bleach food starches, and to inhibit "browning" in bottled lemon juice and virtually all processed potatoes. Sulfur is readily digested by the human body and is one small component of fats, bodily fluids, and skeletal minerals and is essential to life itself.

Wine producers worldwide have been using sulfur for centuries, primarily to prevent spoilage from bacteria and oxidation and to improve color. The wine industry would readily accept an alternative that has the benefits of sulfur without the potential side effects, but no other compound has yet been found that provides all the beneficial effects of sulfur while being so relatively benign.

According to the U.S. Food and Drug Administration, approximately 1% of the population has some sensitivity to sulfur compounds and sulfites and about 5% of asthma sufferers can have adverse sulfite reactions. Asthmatics who depend on corticosteroids are especially prone to sulfite sensitivity and can have severe reactions (the Mayo Clinic web site has additional information).

Prior to enactment, the BATF (now known as TTB) informed the wine industry a sulfite disclosure requirement was pending. They allowed the wineries, through the Wine Institute, to suggest the criteria that would be used. Large wineries used their economic leverage and political power to make certain the regulation would apply to all wines bottled, including those from wineries that use low-sulfur technology and even those that do no sulfur additions whatsoever.

The maximum amount of sulfites allowed in wine sold in the U.S.A., to legally avoid affixing a sulfite disclosure statement, is only 10 ppm. The maximum legal limit for sulfites in wine in most countries is about 335-350 parts per million. In practice, the average amount of sulfites in bottled wine is between 20 and 50 ppm. This is a much lower level than virtually all sulfur-containing processed foods, which may range from as little as 6 to 6,000 ppm. The maximum legal limit for sulfites in dried fruit, for example, is 2000 parts per million.

Some sulfur is naturally occurring in the environment and in grapes, as well as in nearly all fruit and vegetables. Even without the addition of sulfur, yeast fermentation produces a natural sulfur level of between 15-20 ppm, so it is virtually impossible to avoid this labeling requirement. There are no wines that are sulfite-free.

GOVERNMENT HEALTH WARNING

Any alcoholic beverage bottled or imported for sale or distribution in the United States since November 18, 1989, must have a health warning statement on the label. These warnings may contain any of several specific messages, such as:

GOVERNMENT WARNING: (1) ACCORDING TO THE SURGEON GENERAL, WOMEN SHOULD NOT DRINK ALCOHOLIC BEVERAGES DURING PREGNANCY BECAUSE OF THE RISK OF BIRTH DEFECTS. (2) CONSUMPTION OF ALCOHOLIC BEVERAGES IMPAIRS YOUR ABILITY TO DRIVE A CAR OR OPERATE MACHINERY, AND MAY CAUSE HEALTH PROBLEMS.
BACK
(to LEGAL ENTANGLE...)

NO LEGAL STANDING

In addition to the mandatory list, there are terms that commonly appear on wine labels that have no legal definition or regulation. They are primarily marketing terms used to encourage purchase or to designate levels of price and/or quality within a brand line.

"The word Reserve is so prolific in the marketplace that its meaning has been lost, resulting in consumer confusion," to quote the Wine Institute, from its 1994 petition to the BATF (TTB) requesting a definition and ruling on usage. This includes many forms, such as "Proprietor's Reserve", "Winemaker's Reserve", etc. Some countries in the European Common Market will not allow the importation of any U.S. wines using unregulated terms on the labels. Such terms as "Special Selection", "Private Stock", "Limited Release", or any other implication of rarity or quality are in the same category.

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NOTES:

2. From its creation in 1972, until January, 2003, this Department of the Treasury division was called the Bureau of Alcohol, Tobacco and Firearms (BATF). Among other, more obvious measures, the Homeland Security Act separated weapons and crime from the BATF functions. Responsibility for regulation of firearms and explosives, along with arson and criminal investigations involving alcohol and tobacco, such as smuggling, went to the Justice Department.

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Jim LaMar is editor of Professional Friends of Wine, instructs Introductory Sensory Evaluation of Wine at California State University, Fresno, and has been drinking, thinking, teaching and writing about wine for 30 years. He is a member of Professional Friends of Wine.

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