Nutrition Labeling for Wine on the Horizon

Nutrition Labeling for Wine on the Horizon

Joel Butler, MW, isn’t convinced that adding nutrition and ingredient labels to wine will make much difference. “When someone orders a bottle of wine for dinner, they want a good bottle,” he says. “They’re not so much concerned with what’s in it.”

Yet when Butler attended a dinner with other Masters of Wine this past winter in Seattle, he asked the dozen or so people in attendance what they thought about labels. The results—split down the middle, younger versus older—surprised him.

“There was a lot more support than I thought,” says Butler, a Seattle-area wine writer, author, and consultant. “I personally don’t think it would matter much on-premise, but I can see that there is a group of younger sommeliers who think it’s a good idea and who are much more interested in the idea.”

Traditionally, in the US, wine was thought to be above the label debate. It wasn’t canned soup or breakfast cereal, so why did it need to be treated as such? In addition, the American wine industry offered a host of reasons why labels wouldn’t work. Where would they be placed? How could a small winery afford to include them? And two leading wine trade groups, California’s Wine Institute and WineAmerica, always opposed adding labels.

But that changed this year. Or, as Michael Kaiser, WineAmerica’s executive vice-president and director of government affairs, put it bluntly, “Labels may be inevitable.”

The difference? Today, there is growing pressure from several consumer groups and from the Biden Administration, which is reexamining how the federal government should regulate alcohol and reviewing competition within the beverage industry. But, perhaps most important, the next couple of generations of wine producers, retailers, and on-premise operators—those whose opinions surprised Butler at the Seattle dinner—have a perspective that differs from that of generations past.

“I’m all for more transparency,” says Clara Klein, the thirtysomething lead sommelier at Sunday Vinyl, in Denver. “How the wine is made, where it’s coming from, how it’s farmed—and if we can get that all in one step, I’m for it.”

A Long and Tangled History

There has been a move toward soup-style ingredient and nutritional labels for wine, called serving facts, since the late 1990s. The US Department of the Treasury’s Alcohol and Tobacco Tax and Trade Bureau, or TTB, which oversees alcohol regulation, first asked for public comment on serving facts in 2003. This was part of a trend toward increased ingredient transparency for alcohol, supported by several prominent consumer groups, including the Center for Science in the Public Interest. The proposed serving facts were different from the ones that appear on alcohol products such as light beer. Federal law requires goods that make nutritional claims to have labels, and since producers of light beer claims that it has fewer calories than “regular” beer, the calories must be listed.

At the time, the TTB expected labels to be on wine bottles by 2010. Yet the presidential administrations of the first decades of this century didn’t push the issue forward, and the alcohol industry was resistant. Craft brewers particularly objected to calorie labeling, which revolved around serving size. The original proposal stated that the more alcohol in a product, the smaller the serving size. This was anathema to craft brewers, who didn’t believe their 10% ABV beers should be penalized for having more alcohol than 5% ABV mass-market beers.

The wine business was even more obstinate in its resistance during the period from 2008 to 2010. This was perhaps best demonstrated by an article published in Wines & Vines in 2008, written by the former WineAmerica president Bill Nelson. He went directly to the point, writing, “The difference is that wine is not a ‘manufactured’ product produced to constant specification, and nutrition labeling of wine can be misleading.”

Broadly, the wine business opposed ingredient and nutrition labels for three reasons. The first of these was back label clutter. Back labels are key marketing tools, and the space for marketing would be limited if the back label had a serving facts box as well as the UPC code, federal alcohol warning, sulfite and alcohol declarations, and producer, bottler, and importer information. Wineries, particularly small ones, were also concerned about the expense. How could a winery with only a handful of employees afford to determine the calories, sugar, and ingredients every vintage and print new labels each year? Finally, the wine business questioned whether it was possible to enforce a US law on imported wine. If not, wines imported to the US from other countries would have a competitive advantage over domestic wines.

But there was another objection, though it was rarely discussed and almost never on the record. Occasionally, someone in the wine business might comment that winemaking is a complicated process and that consumers would be even more confused if they saw ingredients on a label, as Nelson mentioned in his article in Wines & Vines.

It was left to a handful of troublemakers, such as Bonny Doon’s Randall Grahm, to speak out. Grahm and others argued that wineries didn’t want to include serving facts because they had something to hide, whether using grape juice concentrates like Mega Purple; oak chips instead of oak barrels; or products like polyvinylpolypyrrolidone, a filtering agent (also widely used in pharmaceuticals and dentures). There are more than 60 approved winemaking materials. How would consumers react when they found out that their $25, 93-point wine had a lot more in it than grapes and yeast?

“Consumers have a right to know what’s in their wine,” Grahm said recently, commenting that additives are a crutch to make wine easier to produce. “If you had to put everything on the label that you put in the wine, you’d have to be a much more fastidious winemaker.”

Coming Full Circle

In 2013, the TTB passed a rule permitting voluntary ingredient labeling, allowing alcohol producers who wanted to list ingredients to do so. Not surprisingly, very few wine producers did, save for Ridge Vineyards, Bonny Doon, and an assortment of small, regional wineries. Some of the world’s biggest spirits and beer producers, who wanted to demonstrate the so-called purity of their products, listed serving facts as well. In 2019, for example, Budweiser added a giant serving facts box to a 12-pack of beer. An Anheuser-Busch marketing executive told the Associated Press, “We want to be transparent and give people the thing they are used to seeing.”

As for wine, industry groups said the issue was closed. But, of course, it wasn’t. Over the past decade, several unexpected trends have developed. Younger wine professionals have been thinking more critically about what is going into the wine they sell and make.

“Personally, I appreciate ingredient labeling,” says Nick Vorpagel, whose family owns Lake Geneva Country Meats, a grocery and wine shop in southern Wisconsin, and who is in his 40s. “I care more and more about what I consume and want to ensure I’m eliminating as many processed ingredients as possible. I think it’s a fair request to winemakers to put their ingredients on the label.”

Concurrent with this has been the growth of the natural wine movement, which emphasizes that less is better. It’s not so much that natural wine started taking such a huge market share that the industry had to pay attention. Rather, natural wine became influential among those who were reconsidering what went into their wine.

There has also been a completely unexpected decline in wine drinking among those 60 and younger, as documented in Gallup polls from 2021 and 2022 and in the 2023 Silicon Valley Bank State of the Wine Industry report. Many in the industry believe that the best way to reinvigorate the interest of younger consumers is through transparency in labeling. If wine is a natural product—and the wine business says it is—perhaps emphasizing that fact will attract younger drinkers.

Finally, several consumer groups, led by the Center for Science in the Public Interest, filed suit against the federal government last year for not following through on what the lawsuit called the TTB’s 2003 promise to mandate serving facts. The lawsuit stated alcohol labeling should provide “the same basic transparency consumers expect in foods.” Not coincidentally, the Biden Administration targeted the alcohol business in a 2022 Treasury report, outlining several anticompetitive behaviors, including wholesaler consolidation.

Shortly after these developments, the TTB began the process to add serving facts, which will include one public comment period for ingredients and allergens and two for nutrition. The timeline is uncertain; wine professionals who follow the subject think that the TTB could approve allergens and nutrition labels by the end of this year, with ingredients gaining approval sometime in 2024.

What Consumers Want

None of this addresses whether wine drinkers care about serving facts. What little evidence exists is mixed. Two 2022 surveys—one in the US and one in Europe, with participants in 10 countries, including the US—found that consumers have definite opinions about what they would like to see on wine nutrition and ingredient labels, but they don’t necessarily think that this information is essential.

Stéphane La Guerche, the general manager of France’s International Association of Oenological Products and Practices, worked on the second study. He says, “We didn’t expect precise results, but we were positively surprised about the absence of strong rejection about the presence of additives in a ‘natural product’ such as wine. Some wine professionals were perhaps more pessimistic than consumers on this topic, being afraid about a more negative perception associated [with] a list of ingredients.”

The US study, conducted by the Wine Market Council, reported similar findings. The differences were related to sugar and sulfites. Consumers thought wine had much higher sugar levels than it does, which surprised the researchers, and sulfites were seen as less than natural—and less than healthy.

That’s especially worrisome, says Charles Bieler, who makes wine under a variety of labels in the US and France. “Sulfur dioxide is, of course, something that great wines of the world use to ensure wine protection,” he says, “and we’d need to help a consumer understand that through a common and safe range.”

This is just one part of the conundrum that producers, big and small, must face if serving facts are required. How much is enough? How much is too much?

“We’ve almost never been asked for any of that information,” says Marty Clubb, whose family owns the 50,000-case L’Ecole N° 41, in Washington State. “Yes, sometimes, someone will ask [whether the wines are] vegan, but mostly all our customers are about is what grapes are in the wine.”

Eric Edmunds, the general counsel for the Acheson Group, which advises clients about food ingredient labeling, says the TTB will likely use the Food and Drug Administration (FDA) standards for labeling. This means that compounds that disappear during the winemaking process, such as filtering agents, and techniques, such as spinning to reduce alcohol, probably won’t have to be disclosed.

On the other hand, says Edmunds, FDA standards require listing ingredients that change mouthfeel or overall flavor. For wine, this might include tannic acid or the kind of wood used for aging, whether barrels, staves, chips, or dust. It also means that grape juice concentrates would need to be listed, though the brand name would not be required.

On the Back Label

So what might American ingredient and nutrition labeling information look like? Again, with the caveat that nothing has been decided, this is a best guess from those interviewed for this story:

- A simple listing of ingredients, similar to what Ridge Vineyards and Bonny Doon have on their labels. This might require nothing more than “grapes, grape concentrate, oak tannins, sulfur dioxide, yeast, malolactic bacteria culture.”

- A modified version of the serving facts box seen on other products, but with information relevant to wine, including calories, alcohol, and sugars, though perhaps not fiber or cholesterol.

- An allergen label like what is used on most products, listing allergens, such as eggs, and whether the product was made in a facility where allergens are present. This would probably not require much for wine labels, although, considering grain allergies, it might be relevant for beer and spirits.

The biggest question is, perhaps, how all of this will fit on a wine’s back label. The Europeans, facing an EU deadline to add ingredient and nutrition labels by December 2023, came up with the e-label, a QR code displayed on the back label that links to the winery’s website, where everything that isn’t mandated for the actual label is listed. This will allow wineries to use the same physical label from year to year, simply updating the website each vintage.

Ignacio Sánchez Recarte, the secretary general of the Comité Européen des Entreprises Vins trade group, says, “There was big pressure at EU level for eliminating the exemption for communicating the list of ingredients and the nutrition declaration. But instead of waiting for a commission proposal or, even worse, [seeing] member states adopt national legislation, we decided to proactively request the adoption of rules for wines and aromatized wine products.”

That compromise, say several US trade group officials, is their goal: a QR code and requirements that are similar to those of the EU. That way, the labels would be less burdensome for domestic producers, imports, and US exports to the EU.

Patrick Mata is a co-owner of Olé & Obrigado, which imports Spanish and Portuguese wines to the US and sells them in Europe. He says, “We are excited about this [EU] regulation. We also intend to use some of this data in our US back labels, and we think that the more transparency, the better. This is particularly important for the young consumer who cares deeply about ingredients and doesn’t feel heard when wine back labels don’t reveal this information.”

After some two decades of haggling, this perspective leaves reason for optimism that serving facts may eventually work out—and even better than many hope.

You might also like:

Science vs. Romance in Wine, by MW Susan R. Lin [Members only]
Wine Retailers and the Environmental Impact of Packaging, by MW Melissa Saunders [Members only]
Wine Law Expert Guide [Members only]

References

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Cole, Gail. “Will the Treasury report be a boon for direct shipping of alcohol?” Avalara. February 10, 2022. https://www.avalara.com/blog/en/north-america/2022/02/will-the-treasury-report-be-a-boon-for-direct-shipping-of-alcohol.html.

Federal Register. “Promoting Competition in the Beer, Wine, and Spirits Markets.” Docket No. TTB-2021-0007, Notice No. 204. July 28, 2021. https://www.federalregister.gov/documents/2021/07/28/2021-16115/promoting-competition-in-the-beer-wine-and-spirits-markets.

Gallup. “Alcohol and Drinking.” Accessed April 5, 2023. https://news.gallup.com/poll/1582/alcohol-drinking.aspx.

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Saad, Lydia. “What Percentage of Americans Drink Alcohol?” Gallup. December 29, 2022. https://news.gallup.com/poll/467507/percentage-americans-drink-alcohol.aspx.

Shalal, Andrea, and Diane Bartz. “Treasury wants to stir up U.S. alcohol market to help smaller players.” Reuters. February 9, 2022. https://www.reuters.com/business/exclusive-treasury-wants-stir-up-us-alcohol-market-help-smaller-players-2022-02-09/.

Siegel, Jeff. “US Treasury Alcohol Reform Report—Wine Industry Implications.” The Wine Industry Advisor. February 22, 2022. https://wineindustryadvisor.com/2022/02/22/us-treasury-report-alcohol-industry.

Silicon Valley Bank. “State of the US Wine Industry 2023.” Accessed April 5, 2023. https://www.svb.com/trends-insights/reports/wine-report.

The White House. “Executive Order on Promoting Competition in the American Economy.” July 9, 2021. https://www.whitehouse.gov/briefing-room/presidential-actions/2021/07/09/executive-order-on-promoting-competition-in-the-american-economy/.

Wilson Sonsini Goodrich & Rosati. “President Biden Signs Executive Order on Promoting Competition.” July 13, 2021. https://www.jdsupra.com/legalnews/president-biden-signs-executive-order-5523527/.

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