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 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
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:
wines made sparkling
by any of the natural
Carbonated Grape Wine
wine which is injected
with carbon dioxide.
wine made primarily of sound, ripe
wine made primarily of sound, ripe
fruits other than grapes or citrus
Wine from Other Agricultural Products
wine made from sound agricultural
wine having an alcoholic content
of not less than 15 percent by volume, compounded from grape
wine containing added brandy or alcohol, flavored with herbs
and other natural aromatic flavoring materials
wine containing synthetic materials
grape table wine fermented or flavored
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.
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.
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,
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
(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.
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.
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.