Government regulations

Most wine consumers probably understand that when a label states “Napa Valley” or “Mendocino County” or “Finger Lakes Region,” that the wine in the bottle came primarily from the stated regions. A certain comfort level of consumer-friendliness is involved.

Not that I’m being extra-patriotic, especially in these fraught times, but “America” or “American” can be listed on a wine label as the varaplace of origin of the product in the bottle, though we don’t see it often. Not that the country that lies between two shining seas is an American Viticultural Area (AVA), the delineated wine regions regulated by the Alcohol and Tobacco Tax and Trade Bureau (TTB), a division of the Department of the Treasury; it’s too vast for that distinction. AVAs must have, theoretically, some sort of geological, geographical, climatic and historical coherence. I say “theoretically” because not all AVAs seem to benefit from a logical approach and feel quite obviously geared more to marketing purposes than any guidance for consumers. An example is the vast San Francisco Bay AVA, approved in 1999, amended in 2006, and apparently designed to appeal to fans of Tony Bennett.

But let’s get back to America, so to speak, by taking a look at the bottle I present here. This is the Vara Wines Tinto Especial Lot #012, American Table Wine. Notice a few peculiarities. First, there’s no vintage date. Second, in a wine culture that emphasizes the grapes that wines are made from, there’s no mention here of grape varieties, at least not in the leading position. And third, there’s that “American Table Wine” designation.

According to TTB regulations, wines made from cross-state grape origins — that is, the grapes derive from two or more states — have to be termed “American.” And in that circumstance, no vintage dates are allowed on labels, though in this case, the legend “Lot #012” gives away the mystery; the year was 2012. The reason why the wine does not display a prominent mention of a grape is because the primary variety here, tempranillo, is only 62 percent of the blend. To be featured as a sort of branding device, a wine under the “American,” or a broad state-wide designation, must contain at least 75 percent of that variety. Vara Wines doesn’t tell us what states the grapes derive from — not even on the winery’s website — but we do know what the blend is, as stated on the label in small print: 60 percent tempranillo, 28 percent garnacha, 7 percent syrah and 5 percent monastrell (mourvedre). In other words, the wine aims to be an approximation of a Spanish red, an appropriate stance since Vara is the importing and production arm of The International Brand Family of Spanish and American Wines Commemorating Native American and New World History, based in Albuquerque. The cross-state situation becomes more ambiguous, however, when we consider that a few AVAs actually cross the borders of two states, like the Walla Walla AVA in Washington and Oregon.

The wine in question, a sample for review, features a transparent medium ruby hue and pungent aromas of dried red berries, dried Mediterranean herbs and flowers, with emphasis on cherries and currant, cloves and thyme and notes of violets and lilacs; touches of iodine and graphite, leather and loam add depth, while vivid acidity and dusty, slightly shaggy tannins lend depth. 13.5 percent alcohol. Very Good+. About $24.

This post is the first in an occasional series about the regulations that govern the production of wine in America.

Dear Readers: A few days ago I posted an entry to BiggerThanYourHead that brought the number of posts since its beginning in December 2006 to 1,500. That’s an average of 187 posts each year or slightly more than 15 per month. Perhaps it’s time to step back and get a little perspective.

Last week, Jonathan Cristaldi posted to an amusing and educational essay titled “10 Dirty Secrets of Wine (That Nobody Wants to Talk About),” an exercise that received quite a bit of comment on Facebook and on other people’s blogs. In his prefactory remarks, Cristaldi mentions among “sinister forces at play” in the wine world the “in-fighting among critics and bloggers.” Does such “in-fighting” exist, with its implications of envy, rivalry and hurt feelings? If it does, I hadn’t noticed, but perhaps I am isolated in my Slough of Despond here in what’s called the Mid-South.

One of the “10 Dirty Secrets of Wine” in the piece is “Wine Critics are not necessarily more qualified than bloggers.” Not necessarily more qualified. The point I take from this statement is that typically wine critics are regarded as more qualified than bloggers, but surely these loaded terms require definition. I assume that a wine “critic” is a person employed by a newspaper or magazine or online entity who is paid for his or her efforts, hence a “professional.” A wine “blogger” on the other hand is anyone who establishes a blog or has a blog designed and set up and then writes whatever he or she desires about wine, hence an amateur. The Federal Trade Commission certainly adheres to this view. That regulatory body made effective on December 1, 2009, a ruling that bloggers must disclose the source of products they review and whether those products were samples. (Didn’t know that, youngsters?) That stipulation does not apply to writers who review for print media, the assumption being that newspapers and magazines undergo editorial control that somehow makes the process more trustworthy and legitimate.

The distinction between professional and amateur is irksome. The widely held belief is that one is professional if you get paid for what you’re doing, while amateurs perform out of interest, involvement or love (as the word implies) without regular financial compensation. A professional can also be a person who is certified by an overseeing board or entity, having passed certain tests and qualifying procedures; amateurs typically lack such credentials. Yet since reviewing wine or being a wine critic, whether for a print journal or online, tends toward matters of taste and subjectivity, just as reviewing books or music or theater does, notions of who is professional and who is amateur become more tenuous. The real criteria rest in knowledge and experience, sensitivity and imagination and the ability to transform physical and emotional sensations, as well as history and geography, into evocative language.

How does one achieve such a state? Through constant reading and tasting and writing, through seeking out opportunities to experience a wide range of wines through regions and vintages, through travel, if possible, and visits to the home turf where grapes are grown and wine is made. The “professionals” who write for print outlets may possess all sorts of qualifications, but they are not infallible nor do they always display particular artistry or articulateness in their expression; the same may be said of many bloggers. As far as consumers are concerned, they need to find writers or critics or bloggers whose voices they admire and can engage with, whose intellects they find amenable and whose palates they trust. I started writing about wine in a newspaper column in 1984, before many of the marketing and PR people who send me press releases and samples were born, and I continued that weekly, nationally-distributed column for 20 years (and was a full-time reporter and critic). Did that make me a professional? And when I left the newspaper and launched myself online, did I decline from being a professional to being an amateur?

Those issues are ancient history, however, and wine-blogging and critiquing are about the here and now, as each vintage succeeds the one before, and producers around the world watch the weather and the climate for the minute (or dramatic) changes that make each year and harvest different. The issue I really want to approach is my own motivation for adhering to an avocation that takes up a good deal of time and space and produces little material reward except — and this is a big “except” — for the wine samples I receive and the occasional sponsored trip that I go on. My Readers are thinking, “Those should be reasons enough,” and indeed I don’t discount them, but there are other aspects.

Most important is the wine itself — a uniquely complex and evocative beverage and a perpetual reminder of our connection to the earth and its seasons — and the ability to follow producers and wines from year to year. One of the most gratifying factors in this endeavor is the contact I have with new, small wineries that send me their products for review. Next is the responsibility to My Readers, bless their hearts, who depend on me for honest and fair assessments of wines and for supporting historical, geographical and technical information, which to me is an essential part of writing about wine. Then there are the friendships I have made and that I treasure in many moments of tasting wine and food and sharing knowledge and experience and stories of travel and adventure.

Lord knows how many mass tastings I have attended over 30 years, those trade events where journalists carry a glass in one hand and a notebook in the other and move from table to table, producer to producer and swirl-sniff-sip-spit their way through a hundred wines. Not the best way to taste wine, but sometimes such events are the only way to be exposed to a broad range of products. Then there are the weekend mornings when I stand in the kitchen and taste through a dozen cabernets or pinot noirs or rieslings. My favorite way to experience wine though is with dinner at home, when LL and I sit down with a wine that I have held back and open it and take a sniff and taste and look at each other and whisper, “Holy crap, that’s good.”

You see, friends, we’re all amateurs.

The term “small batch” originated in Kentucky’s bourbon industry as a way of indicating that a particular item was limited in production and generally received some sort of special treatment in the way of types of barrels, length of aging and selection of ingredients. Perhaps the classic or best-known roster of small batch bourbons consists of the quartet of Booker’s, Basil Hayden’s, Baker’s and Knob Creek (my favorite), from Beam Global Spirits and Wines Inc.; equally well-regarded are Blanton’s from Eagle Trace Distillery and Brown-Forman’s Woodford Reserve, but mentioning these products doesn’t begin to indicate the number of small batch and single-barrel bourbons and other limited edition whiskeys available, a number that increases every year. The success of these products — for which no real or official definition exists — seems to be fueled by clever marketing toward male and female Millennial consumers and their abiding interest in all things handmade, artisan-like and privileged or for older spirits devotees for whom single-malt Scotch has become too expensive. Not that small batch bourbon is cheap.

So popular is the notion of “small batch” and its implications of craft and care and specialness that the term has spread into or been hijacked by products in many other areas. As My Readers can see in the accompanying images, “small batch” now applies to soy sauce, tonic and fish sauce, and these are only the items that we happen to have on hand. The problem with the nomenclature of exclusivity, including “small batch,” “artisan,” “craft,” “green” and others, is that they are defined in the most nebulous manner or not at all and that their use has become so widespread as to render them meaningless. Such labels have become mere counters or status indicators in our vast marketplace’s tyranny of choice.

The situation is similar in the American wine industry, in which labeling lingo like “reserve,” “old vines,” “limited production” and a variety of other terms proliferate and are entirely unregulated; I mean, what does “Vintner’s Reserve” mean? No producers in California, of course, want more federal interference with labeling or vineyard and winery practices, yet wouldn’t consumers benefit if they knew that for a particular Reserve Cabernet Sauvignon meant 1,000 cases as opposed to a “regular” bottling of 20,000 cases or that “Old Vines” actually meant that a wine was produced from a vineyard where the vines were planted in 1919? Without some sort of indication, terms like “reserve” and “old vines” are as meaningless as “green” or “artisan” on a box of “gourmet” crackers.

Not that, as in Europe, such notions as “reserve” such be regulated precisely, but neither is it sufficient that labels offer such vague reassurance as “Our Reserve Cabernet is strictly limited in production” or “Our Old Vine Zinfandel was made from our historic and heritage vineyards in Sonoma Valley.” Posh! Just tell us how limited that production was or how old those vines are. It’s that simple. I don’t think we need state or federal rulings that a reserve wine must be limited to a certain number of cases and aged according to a determined regimen or that “old vine” must mean older than 50 years, as long as producers tell us what the details are. And that goes for “small batch” bourbon, soy sauce and tonic too. Any term that’s imprecise or used as esthetic, ethical or moral coding is just a marketing tool intended to impress, coerce or confuse the consumer.
So, how “small batch” is a small batch bourbon? Beam’s Knob Creek is produced in about 200,000 cases annually, compared to Jim Beam, which totals about 6 million cases. Some 160,000 cases of Woodford Reserve were made in 2010; Jack Daniels comes in at nearly 10 million cases. It took a considerable amount of time on Google to find these figures. Small batch whiskeys made by smaller distilleries may be much more limited.

You’ll notice that the soy sauce pictured above, made in Louisville by the Bluegrass Soy Sauce Co., is not only “small batch” but “microbrewed” and “single barrel.” The wraparound label indicates that the bottle sitting on the desk next to me is No. 89 from batch 340-10. In terms of soy sauce, this attention to minutiae is either inspiring or precious, but we still don’t know how small this “small batch” is.

My recent sojourn in Bordeaux brought pleasures and revelations of many kinds — people, places, wine, food, history, tradition — but the most acute revelation, in fact the big story, occurred on the last night, when our small group had a tour, tasting and casual dinner at Domaine de Cantemerle — not to be confused with Chateau Cantemerle, the Fifth Growth Haut-Medoc estate in the commune of Macau. The proprietor of Domaine de Cantemerle is 73-year-old polymath Christian Mabille, who with his three sons in 1998 took over the property whose origins go back to the early 19th Century. Mabille, who seems as fluent in English as he wants to be, mainly spoke French when we visited the producer of Bordeaux Supérieur wines that lies about 20 kilometers north of the city of Bordeaux, on the right bank of the Dordogne river, in the commune of Saint-Gervais. (The domaine’s wines are available in New Jersey, California, New York, Connecticut, Illinois, Virginia, Washington D.C., Missouri and Michigan.)

We were enjoying a meal of charcuterie and cheeses in one of the winery’s barrel rooms when Mabille, who is not immune to the twinkling eye and well-placed bon mot, dropped this bomb: “We are trying to anticipate climate change by bringing in chardonnay and other white varieties to replace sauvignon blanc, which is not going to be appropriate in a few more years.”

My colleagues and I scrambled for our notebooks. Chardonnay in Bordeaux? Sacre bleu!

I won’t belabor the point, but to recap briefly, grape-growing and wine-production in France are heavily regulated by the INAO through the AOC system. Each region where grapes are grown and wine is made, from the tiniest, most obscure appellation to the vast and geographically sweeping, is subject to rules that determine what grapes are entitled to be cultivated, how abundant the yields can be, whether certain vineyard and winery practices are allowed (irrigation, chaptalization) and how wines from specific areas are to be labeled. In fact, regulations were recently enacted that determine how many meters high vines can grow for some appellations, though there’s a five-year grace period to retool vineyards, as it were.

No rules exist that say that chardonnay grapes cannot be grown in Bordeaux and that wine cannot be made from those grapes; you just can’t label that wine as being from Bordeaux or anywhere within Bordeaux. The white grapes allowed in Bordeaux are sauvignon blanc, semillon and muscadelle along with a few others like ugni blanc and colombard not used for top-flight wines. Chardonnay is not one of those permitted white grapes, primarily for reasons of practicality; chardonnay grapes to not perform at their best in Bordeaux’s maritime climate.

Mabille’s point is that as climate change continues to alter traditional weather-patterns and the gradual warming of the region becomes more acute, chardonnay and several other white varieties common to the South of France — Mabille is looking in Corbieres — will not only be suited to Bordeaux but necessary if the region is going to continue to produce white wine.

“We’ll only plant one or two hectares,” said Mabille — 2.57 to 5.14 acres — “just as an experiment, and this will happen in a year or two. Everything is in place. We have chosen the root stock and the vines, we have made cuttings, but the hail in September set us back.” (The domaine lost half of its crop of 2011 because of hail.) “Of course the wines will have to be made as Vin de France,” that is, they will not be allowed to carry any Bordeaux designation, a prospect that doesn’t bother Mabille because the domaine’s rosé is bottled as Vin de Table. “We wanted to give our rose a different character that’s not typical of Bordeaux rosés,” he said, “something a little darker, with a little more residual sugar. We didn’t want to confuse things administratively.”

Most startling was Mabille’s attitude toward the AOC structure: “It’s no longer a question of regulations,” he said, “but of client and customer confidence.” He goes further: “In this region, of course we have the traditional varieties, but you know carmenere has almost disappeared and petit verdot is no longer found in the northern Gironde except right here.” (Petit verdot makes up about one percent of the domaine’s 115 acres.) “Even the traditional producers and merchants have accepted that a part of the old grape varieties of Bordeaux are no longer present or viable.”

In fact, Mabille believes that the entire regulatory system needs rethinking.

“In 10 or 15 years, the AOC rules must be changed to allow more grape varieties,” he said, “or the whole thing is just going to blow to pieces. As I travel to other regions of the country and the world, I note that the French appellation system is very much appreciated and admired but not fully copied because it goes too far, it is too complicated. It’s essential to have rules, but they shouldn’t be extreme. I really support the changes to a simplified EU system that are coming in the future. It’s inevitable.”

Photo of Corie Brown, of, and FK frantically taking notes was shot by Fred Minnick. Many thanks to Jana Kravitz for her heroic translating efforts on this occasion.

As a basic concept, a Bordeaux wine is any wine made within the defined region of Bordeaux, a geographical but not a political entity in the Gironde départment in southwest France. Within Bordeaux, however, there are 57 separate appellations, that is, official growing and winemaking areas defined by the INAO, the Institut National des Appellations d’Origine, established in 1935 and taxed with regulating (in great detail) some 470 wines and spirits as well as other agricultural products. The fact that a region like Bordeaux consists of 57 appellations might seem difficult enough to encompass, though the system is further complicated by the existence of different rules within appellations — white wine made in Margaux, for example, cannot be designated as Margaux AOC — and by certain limited choices of designation that producers can make.

Bordeaux, in its most celebrated guise, is home to some of the world’s greatest wine estates, well-nigh legendary properties that annually release to the waiting arms and open pocketbooks of connoisseurs, collectors and high-end restaurants wines of finesse, breeding, power and longevity. These wines, famous indeed but only about five percent of the region’s total production, tend to originate in the appellations of Graves, Pessac-Léognan, Margaux, Pauillac, St.-Estephe, St.-Julien, Pomerol and St.-Emilion, all for red wine, and Sauternes and Barsac for dessert wines. Most of these appellations are communal, meaning that they are named for old towns and villages around which the vineyards and chateaux cluster.

In the regional sense, however — and let’s not forget that Bordeaux is also a city on the Garonne river that has been a center of wine-trading for eight centuries — in the narrowly (or formally) determined sense, the word “Bordeaux” officially applies to seven of the 57 appellations according to the A.O.C (Appellation d’Origine Côntrolée) regulations: Bordeaux Red; Bordeaux Supérieur Red; Bordeaux White; Bordeaux Supérieur White; Bordeaux Rosé; Bordeaux Clairet; and Crémant de Bordeaux — yes, small amounts of champagne method sparkling wine are produced in Bordeaux, and its quite tasty, if generally simple and direct. These seven appellations and their growers are represented by the Syndicat Viticole des AOC Bordeaux et Bordeaux Supérieur from its headquarters at Planete Bordeaux in Beychac et Caillau, just south of the Dordogne river in Entre-Deux-Mers.

The vineyards that supply the grapes for the seven “Bordeaux” appellations account for 54 percent of Bordeaux’s vineyard area, some 61,000 hectares, or about 156,770 acres. These vineyards are farmed by 6,085 growers, many of whom make, bottle and market their own wines, though the majority sell either grapes or wine to cooperatives, of which there are 44. The average holding for each grower is just under 26 acres; these are not large landowners, and they do not sell their wines for hefty prices. Obviously we are talking about a realm far removed from the heady preserves of the Classified Growths and grand chateaux nestled in their parks and illustrious, historic vineyards from which spring the hallowed, long-lived wines — Lafite-Rothschild, Latour, Margaux, Haut-Brion, Mouton-Rothschild, Petrus, Ausone, Cheval Blanc and so forth — that command tremendous feats of fiduciary prowess on the part of American CEOs and Asian magnates. No, I am writing here of smaller, more intimate chateaux, glorified farmhouses really, surrounded by a few hectares of vines often tended by the same families for generations, even back to the 18th Century. (Let me add that there are many beautiful old estates and chateaux in all regions and appellations of Bordeaux.)

Like the tremendous gulf that yawns between the salaries of business leaders and wage-earners in America, the untenable gap between the prices fetched for the top five percent of Bordeaux wines and the rest of the vast sea of wine produced in the region is economically insupportable. And where are these small landowners going to sell their products now that the French consume less wine than at any point since records began being kept yet more wine — a glut of wine — is being made? (Answer: The United States of America and the People’s Republic of China.)

Anyway, the differences between Bordeaux AOC and Bordeaux Supérieur AOC are matters of degrees. Bordeaux Supérieur red wine is supposed to be made from older vines (though the age is unspecified in the regulations) and aged for 12 months; it must finish with a minimum of 10.5 percent alcohol, as opposed to the minimum of 10 percent for “regular” Bordeaux, though the reality is that almost all the wines produced from both appellations vary from about 11.5 to 13.5 percent. The “Supérieur” designation does not mean that the wine is inherently “better” or “superior” to a wine that carries a plainer “Bordeaux” designation; the implication, however, is that because the rules are slightly more demanding, the possibility exists that a Bordeaux Supérieur wine would display more character and be capable of aging for four or five years.

One may think of Bordeaux, then, as a structure of concentric circles, with Bordeaux AOC and Bordeaux Supérieur AOC, which may be made anywhere in the overall Bordeaux region, as the outer circles, while the rest of the (theoretical) circles become smaller and smaller, until finally we come to the communal appellations and their Classified Growths. Bordeaux Rosé AOC, Clairet and Crémant can also be made anywhere in the Bordeaux region, but you can bet that such production is limited to the broad AOCs; the winemakers at Classified Growths have better things to do with their expensive pedigreed grapes than knock out a few cases of rosé. There’s always the possibility that an estate could take advantage of the allowance to declassify a wine to Bordeaux AOC in an irregular year, though that decision has to be reached before the wine is made, not after; Bordeaux AOC and Bordeaux Supérieur AOC are not to be used as dumping appellations for inferior or mediocre wines.

Thanks to Jana Kravitz of Vin’Animus for clearing up some points of confusion; if there’s anything confusing in this account, it’s my fault. Image of the old port of Bordeaux from

At a press conference on the future of Italian wine in America — last week at VINO 2011 in New York — importer Leonardo LoCascio startled everyone — well, me — by asserting that American consumers don’t give a flying fuck (that’s not exactly what he said) about the regional niceties of the elaborate Italian DOC and DOCG regulations that determine where grapes can be grown and how they may be blended (if at all) in specific wines and how those wines must be treated in terms of barrel and bottle aging.

“Most of the Italian wine laws are irrelevant to the American consumer,” said LoCascio, founder, chairman and CEO of Winebow Inc. “These regulations are totally meaningless as to whether people buy a wine or not. Everything needs to be simplified.” And he mentioned in passing some little-known DOC zone with the implication that it was completely beyond the pale in terms of marketing interest in the U.S.

It’s true that Italian wine and the Italian wine laws are complicated and often confusing. Over 2,000 grape varieties are officially grown in the country’s 20 broad wine regions — they conform to the boot-shaped nation’s administrative divisions — portioned into something like 311 DOC zones, 39 DOCG zones and 120 IGT zones that produce more than 1200 different wines. Many of these areas are tiny and obscure and produce minute quantities of wine from grapes no one has heard of outside the neighborhood. (The abbreviations stand for Denominazione di origine controllata; Denominazione de origine controllata garantita, a theoretically higher category with stricter controls and “guarantees,” and notice that I say “theoretically”; and Indicazione geografica tipica, for a wine that does not fit into the traditional grape heritage of a region or vineyard area.)

Now I’m not about to contradict the authority of one of this country’s leading importers of Italian wines from all regions, the man who practically singlehandedly persuaded Americans to drink the wines of Apulia, and LoCascio may be correct when it comes to Mr. or Ms. Average American Wine Consumer (AvAmWinC) who just wants to pick up a bottle of pleasant, quaffable pinot grigio to knock back with a bowl of potato chips before dinner. These people, I vouchsafe, probably don’t care a hoot whether their pinot grigio hales from Collio Goriziano or Valle Isarco or Blanc de Morgex et de la Selle (yes, that’s in Italy).

There is, on the other hand, a group of people for whom the notion of regional authenticity rates high on the scale of their aesthetic and moral principles. These are the people who care whence their coffee and and tea and chocolate originate, down to the name of the plantation; who eat on a strictly seasonal basis from local food sources; who buy organic and healthy ingredients whenever possible; who want the wine they drink to be made naturally and traditionally, the consumers who care deeply (perhaps maddeningly so) about the notions of integrity and authenticity that regionality signifies. These concepts form the whole basis of the international Slow Food movement, which started in Italy, and the related locavore phenomenon, and if those social and cultural directions appeal to a minority of Americans, let’s remember, in vinous terms, that only 20 percent of Americans who drink wine drink 90 percent of the wine that gets drunk. These people are serious, and they spend money.

As for me, the more regional the better! I was pleased as punch to try wines at VINO 2011 from Italian DOC zones that I had not encountered before, especially in Lombardy. And to move the discussion out of Italy, a few days ago I made my Wine of the Week a juicy tasty garnacha from Spain’s Vino de la Tierra del Bajo Aragón, another region that was new to me. Somebody is sending me a wine from — New Jersey! The Outer Coastal AVA! I can’t wait!

Of course just because a wine is made by a venerable family on an ancient farm in some dim, out-of-the-way valley using only the most traditional methods and gluing the labels on the (recycled) bottles by hand doesn’t guarantee a great or even good wine. Intentions count, but not much. My point, though, is that we must value individuality, integrity and authenticity, even some eccentricity, if we are to participate truly in a global wine world that does not become homogenized or “pinot-grigioized” into universal innocuousness.

Will it really help sell wines from Russian River Valley or Alexander Valley if labels for wines from those appellations are required by law to state “Sonoma County” as well as the region?

The trade group Sonoma County Vintners is proposing such a law for so-called “conjunctive labeling” to the state legislature, on the model of a similar law passed in the 1980s for Napa Valley. The idea is to raise recognition for the county as a winemaking region; in other words, this law would be all about marketing. As Tom Wark eloquently points out in his post on this subject on his blog Fermentation, wineries in any of the county’s 13 distinct American Viticultural Areas (AVAs) may append the words “Sonoma County” to their regional designation if they want do, but they may also choose not to; most of them, it seems, do not. After all, labeling practices are in the hands of the Federal Alcohol and Tobacco Trade and Tax Bureau (TTB), which sets the regulations for wine labeling and geographical matters. Why should local authorities try to trump the feds and add even more rules to a complicated business?

And why would a producer in Russian River Valley or Dry Creek Valley not want to have the term “Sonoma County” added to a wine’s front label?

Sonoma County encompasses 13 growing regions (AVAs) that total about 60,300 acres of vines. Theoretically, the different official areas — “official” because they are determined and recognized by the federal government — display distinct enough characteristics to justify their existence, for example, Russian River Valley with its low-lying riverine topography and propensity to morning fog; the warmer Alexander Valley; gently rolling Chalk Hill, with its soil of volcanic ash. The implication (or hope) is that each distinct AVA contributes unique elements of geography and climate to the formation of a wine’s style and character.

“Sonoma County,” on the other hand, is such a broad category that its most legitimate function is as a generic geographic indicator, a way of saying, “This wine was made in a certain county in Northern California.” Such a condition is not necessarily pejorative, especially for inexpensive or moderately-priced wines whose grapes may be blended from several smaller AVAs, of which there are many examples. The point is that there is not an identifiable “Sonoma County” character that can be ascribed to a wine.

If, however, a producer is making prestige-level wines from smaller AVAs with the intention of reflecting the specific influence of that soil and micro-climate in the wine, then adding the term “Sonoma County” to the front label is not merely redundant but distracting. That front label is the billboard, the “Hollywood” sign of a wine bottle; it’s the field where producers state what they think is most important and immediately recognizable about their wines.

Being curious about how many wineries or producers in Sonoma County actually use the “Sonoma County” terms on the front label as well as a smaller AVA, I looked through the review sample rack and refrigerator for examples, and here’s what I came up:

Those That Do Not Mention Sonoma County on the Front Label
<>Frei Brothers Reserve Syrah 2007, Russian River Valley, Northern Sonoma. (The largely useless Northern Sonoma AVA encompasses all of Sonoma County except for the Sonoma Valley and Carneros appellations. It was created in 1985 — and amended in 1986 and 1990 — after a campaign by E & J Gallo. Frei Brothers is a Gallo brand.)

<>Terlato Pinot Noir 2007, Russian River Valley.

<>Sausal Private Reserve Zinfandel 2007, Alexander Valley.

<>Benovia Bella Una Pinot Noir 2007, Russian River Valley.

<>Dry Creek Vineyard The Mariner Meritage 2006, Dry Creek Valley. (Sonoma County stated on back label.)

<>Benziger Signaterra Three Block 2006, Sonoma Valley.

<>La Crema Pinot Noir 2008, Sonoma Coast.

<>Davis Bynum Pinot Noir 2007, Russian River Valley.

<>Louis M. Martini Reserve Cabernet Sauvignon 2003, Alexander Valley. (Yeah, I know, why do I still have this wine?)

<>Respite Reichel Vineyard Cabernet Sauvignon 2006, Alexander Valley.

<>Gundlach Bundschu Rhinefarm Vineyard Merlot 2005, Sonoma Valley.

<>EnRoute Les Pommiers Pinot Noir 2008, Russian River Valley.

<>Silver Oak Cabernet Sauvignon 1998, Alexander Valley. (Not a review sample, of course; I bought this at an auction. Perhaps I should drink it with tonight’s pizza.)

<>Thumbprint Cellars Westside Vineyard Chardonnay 2007, Russian River Valley.

<>Hook & Ladder “Third Alarm” Reserve Chardonnay 2003, Russian River Valley. (Why do I still have this wine, too?)

Those That Mention Sonoma County on the Front Label as Well as a Distinct Appellation
<>Murphy-Goode Merlot 2007, Alexander Valley, Sonoma County.

<>Matanzas Creek Merlot 2006, Bennett Valley, Sonoma County.

<>Rodney Strong Brothers Ridge Cabernet Sauvignon 2006, Alexander Valley, Sonoma County.

Admittedly this is an anecdotal survey with a plus/minus factor of probably 10,000 percent, but it also speaks pretty clearly; 14 wineries use the specific appellation name without adding Sonoma County, while three do. Yet according to an article by Kevin McCallum in The [Santa Rosa] Press Democrat, “Eight of the county’s nine wine and grape trade groups say they would support a law that would require wines made from local grapes to feature Sonoma County on the label.” The ninth trade group, that of Russian River Valley, is also considered a shoo-in.

What the hell, readers? I mean, I won’t even speculate on the motivations behind these bewildering votes, because I can’t fathom it.

And as I look at other wine labels of bottles clustered about me in phalanxes of rectitude, I can’t help noting that most of them to do not include a broader county designation in addition to a specific appellation. Right at hand are two bottles of wine from Heller Estate that say, “Carmel Valley, California,” but don’t mention Monterey County. Similarly, bottles of vineyard designated pinot noir from Lucienne say “Santa Lucia Highlands,” without mentioning Monterey County. Here’s an Easton Zinfandel 2006 from Fiddletown that doesn’t mention Amador County. And so on.

The exception to these examples, as I mentioned earlier, is Napa Valley, but notice that the legal requirement doesn’t insist on including the term Napa County. Yes, Napa County is also a designated AVA — it’s slightly larger than Napa Valley — and wineries could use the term if they wanted to. I’m sure you have noticed that almost no one does. I mean, who wants to be known as a producer of Napa County wines?

Map of Sonoma County AVAs from

There are two problems with the new guidelines issued this week by the Federal Trade Commission that stipulate that bloggers and other new media writers disclose the sources of the products they review, i.e. if they were free samples. And no, that particular rule isn’t one of the problems. Many wine bloggers already post disclaimers so that readers know that wines being reviewed were sent from wineries or importers or their representatives in hopes of a mention of some kind, preferably positive. And many wine bloggers make it clear that wineries from which they receive samples should have no expectation as to whether a review will be positive or negative or even if the wine will be reviewed at all; that’s exactly as it should be.

No, the first problem, as Tom Wark pointed out eloquently on his blog Fermentation yesterday, is that the FTC’s new disclosure rules do not apply to “traditional” print media because they, presumably, exercise more editorial control over their material and coverage than the rank amateurs of the blogosphere. So publications like Wine Spectator, Wine Enthusiast and Wine & Spirits, which receive untold thousands of bottles of wine free every year, do not need to disclose that fact to their readers, while a first-time wine blogger, who might feel grateful for a few review samples, must do so. This is a situation for which the phrase “The Double Standard Stinks” was invented.

The second problem is that the drafters of the new FTC guidelines don’t seem to know a hawk from a handsaw when it comes to the difference between a review and an endorsement. The report expresses the principle this way:

“For example, a blogger could receive merchandise from a marketer with a request to review it, but with no compensation paid other than the value of the product itself. In this situation, whether or not any positive statement the blogger posts would be deemed an ‘endorsement’ within the meaning of the Guides would depend on, among other things, the value of that product, and on whether the blogger routinely receives such requests. If that blogger frequently receives products from manufacturers because he or she is known to have wide readership within a particular demographic group that is the manufacturers’ target market, the blogger’s statements are likely to be deemed to be ‘endorsements,’ as are postings by participants in network marketing programs.”

Obviously the FTC equates positive reviews with “endorsements,” as if bloggers were celebrity basketball players on billboards being paid hundreds of thousands or millions of dollars to put the force of their internationally known, outsize personalities at the service of athletic shoes and energy drinks. (If only, right?)

A review or critique of anything — book, musical recording, an art exhibition or theatrical performance, a product such as an automobile or a dishwasher, or a bottle of wine — is (or should be) an assessment and evaluation based on knowledge, experience and judgment. For the reader, the benefit lies in the information and analysis upon which to base a decision, to go see that play, to read that book, to purchase that bottle of wine. This result is not the same as an endorsement, in which a celebrity is paid to mouth words conceived by a copy-writer from a marketing or public relations firm. A review is not an advertisement or press release for the object or performance or entity in question.

Yet, annoyingly, the new FTC guidelines refer, again and again, to reviews on blogs as endorsements and to companies that supply products to bloggers for review as advertisers. The case seems devastatingly clear: If I were sent a review copy of a book by a publisher and wrote a review that was published in a print journal or newspaper, the FTC would regard it as a review; if I wrote that review, however, and placed it on my blog, it would be regarded by the FTC as an endorsement for the book, going on the supposition that my blog lacks traditional “editorial responsibility.” And notice, in the quotation from the guidelines above, that the bigger the audience for the blog, the more likely that a review will be considered an endorsement. This is the sort of obtuse reasoning from which Circles of Hell are fashioned.

It’s possible that these guidelines — only a small portion of the 81-page document that focuses primarily on television and magazine advertising — were deemed necessary by the FTC because of the bloggers who review a variety of mainly household products only in a positive manner. Well-known examples of these are the “mommy bloggers” Katja Presnal at and Christine Young of As Tim Arango wrote yesterday in The New York Times about Christine Young, “If she doesn’t like a product, she simply won’t write about it.”

Now I’m not telling my Fellow Wine-Bloggers to pick out a bottle of wine and kick it in the teeth just for fun, but I will say that giving only positive reviews does not build credibility or a reputation for objectivity. In fact, writing only positive reviews creates the impression that all you’re doing is, yes, endorsing products without engaging a balancing critical sensibility. And providing negative or even not wholly positive reviews is a boon for your readers; doesn’t it make as much sense to warn them away from mediocrity as to extol what is superior?

The FTC guidelines for bloggers take effect on Dec. 1, though the enterprise is fraught with ambiguity. If I write a post in which I review 12 wines, must I include a disclaimer for each wine or a blanket disclaimer for the post? Or is it all right to include a permanent disclaimer for the blog that covers all posts and all wines? The FTC hasn’t made that clear. What is clear is that in the next few months the sort of confusion and consternation that leads to lawsuits will reign.

During the four days that I was in Germany in July, our group heard over and over from producers and winemakers that the Wine Law of 1971 marked a body-blow to the German wine industry from which it has struggled for almost 40 years to recover. Indeed, in his chapter on the Wine Law in The Wines of Germany (Mitchell Beazley, 2003), Stephen Brook uses words like “abuse,” villainous,” “terminological rape” and “inanity” to describe the regulations and their effects. While an explanation of German wine label terms and the strictures of the Wine Law could take a semester of seminars and workshops, let me heroically attempt such a feat in one incredibly over-simplifying blog post.

(This post is not a guide to reading German wine labels. For that precise information go here or here.)

And before we leap to the heart of the matter, let me draw an analogy between the vineyard systems of Burgundy and Germany. In contrast to Bordeaux, for example, where the estate and the wine are synonymous, in Burgundy and Germany the villages and vineyards hold the qualitative pride of place, with many producers making wine from the same vineyard, of which they may own a piece or purchase grapes from another owner. In Bordeaux, for example, Chateau Lafite-Rothschild is the name of the wine and the estate, and its vineyards are its own. On a Burgundy label, the words Volnay Le Cailleret indicate (first) the village and (second) the vineyard, just as on a German label the words Nierstein Ölberg indicate the same village/vineyard sequence. Most of the wine world follows the model of Bordeaux, to greater or lesser degree.

O.K., now, here’s how the German Wine Law struck the death knell for the country’s fine wine estates.

First, the committees that came up with the Wine Laws completely ignored the traditions of quality differences among vineyards. Let’s face it: some vineyards are better than others. That’s why, in Burgundy, for instance, Chambertin-Clos de Bèze, a Grand Cru vineyard, (usually) commands a higher price than Gevry-Chambertin Les Cazetiers, a Premier Cru vineyard, or why, in California, wines made from vineyards with long histories of producing high-quality wines, such as To-Kalon or Sanford & Benedict, are sought after by collectors. What makes one vineyard better than another is a subject for another post or seven, but, briefly, it’s a matter of the nuances of exposure, drainage and soil/sub-soil composition along with variations in the consistency of warmth and coolness during the day and at night. Such details, both minute and sweeping, of geography and micro-climate can change within a few hundred yards or even from one side of a road to the other. Fortunes depend on such subtleties.

As far as the German Wine Law is concerned, however, the greatest virtue of a wine is not where it came from or the grape variety from which it was made but the ripeness of the grapes.

The whole spectrum of German wines falls under these divisions: 1. Deutscher Tafelwein (German table wine); 2. Landwein (country wine); 3. Qualitätswein bestimmer Anbaugebiete (QbA, quality wine of a specified appellation); and 4. Qualitätswein mit Prädikat (QmP, quality wines with distinction). The vast majority of wine made in Germany is Tafelwein and Landwein; few regulations apply to these levels and little is exported. QbA wines — often signified just by the word Qualitätswein on labels — must conform to regional laws and must be tested by a compliance committee; these wines may have sugar added during fermentation to achieve the required level of alcohol.

QmP wines, which may not have sugar added to them, were codified in the German Wine Law of 1971 as such: Kabinett; Spätlese, Auslese; Beerenauslese, Trockenbeerauslese. The categories are defined by law in ascending order, starting with Kabinett, in terms of the ripeness of the grapes and the potential alcohol content (that is to say, from driest to sweetest) and the specific lateness and method of harvest. The Wine Law clearly implies that the ascending order is one of increasing quality; a Spätlese wine, in other words, is inherently “better” than a Kabinett and so on.

Second, the German Wine Law of 1971 shanghaied the names of well-favored villages and attached them to broad regional designations (Grosslages), thereby diluting the reputation of the village and its often illustrious vineyards. “How many people would know,” Brook writes in The Wines of Germany, “that Piesporter Goldtröpfchen was the name of one of the finest sites on the Mosel, while Piersporter Michelsberg was a Grosslage name that incorporated a vast area of utterly mediocre vineyards on overfertile flat land at some distance from the river?” In other words, it is perfectly legal for a wine designated Piesporter Michelsberg to have no wine from Piesport in it.

Obviously this scheme favors large producers who can take advantage of a famous name to display on labels of generic wine. It also favors wine sellers who can persuade their customers to purchase more expensive Spätlese or Auslese wines because they’re “better” than Kabinetts. (I saw a newsletter from a German wine club that described the principle virtue of QbA wines as “to mix with club soda.”)

However, some of the best wines I tried in Germany were Kabinett wines of classic intensity and authority or Spätleses made in the dry or “half-dry” (trocken or halb-trocken) fashion. Other great wines I encountered were QmP wines declassified to QbA or deliberately made outside the QmP system, just as producers in Italy used to opt for the lowly Vino da Tavola designation to make wines from officially unapproved grapes. That’s one method by which fine estates in Germany are trying to produce authentic and individualistic wines without being hampered by illogical regulations.

Another method is the creation of a self-regulating regional Grand Cru (Grosses Gewächs) system designed by the VDP (Verband Deutscher Prädikatsweingüter, the Association of German Prädikat Wine Estates) and legalized in 2006. As admirable, however, as this classification system may be in identifying and supporting Germany’s finest vineyards (though who could say that these choices are not arbitrary to some extent), the VDP’s relentless emphasis lies with dry wines at the Kabinett and Spätlese levels, at the expense of the inimitable dessert wines that are the real glory of Germany’s wine industry. It’s true that in a changing world German wine consumers turn increasingly to dry wines, but the wonderful heritage of that golden nectar must not be minimized or forsaken.

Does the American Wine Consumer actually purchase wine based on the American Viticultural Area designated on the label?

Mr. American Wine Consumer: “Look, honey, this chardonnay is from the Santa Maria Valley, so it must be good!”

Mrs. American Wine Consumer: “”I’ll say, sweetie, let’s get it!”

Mr. AWC: “Okey-dokey!”

Mrs. AWC: “By the way, where is the Santa Maria Valley?”

Mr. AWC: “Oh, you know, in, um, California.”

Not meaning to denigrate the knowledge of Mr. & Mrs. American Wine Consumer; I realize that a lot of people out there haunting the aisles of the nation’s retail stores have a lot of facts about wine in hand. I know that people who really love wine probably understand that there is or can be or ought to be differences between, for example, pinot noir wines made in Anderson Valley, Russian River Valley, Carneros and Santa Lucia Highlands. On the other hand, I would say that most people just want a nice bottle of wine to take home for dinner and rely on experience or the advice of a trusted salesperson or brilliant blogger.

Wine producers, on another hand, are pretty obsessive about the exactitudes of geographical designations, and a great deal of time, effort and money and not a little blood has been spilled in the establishment of AVAs. Petitions for new AVAs appear before the TTB (the federal Alcohol and Tobacco Tax and Trade Bureau) almost weekly. Being able to say on the label, for instance, that one’s wine is from the Napa Valley, because of the region’s historical and qualitative importance, is theoretically more desirable than a broad “California” designation, while a narrower or more specific AVA, like Oakville or Stags Leap within Napa Valley, is theoretically better than just Napa Valley. Carving out a new and distinct AVA can be an important step to legitimizing a winery and its products, at least in the mind of the producer.

This meditation was inspired by a post from September 12 on Tom Wark’s Fermentation called “Let Russian River Valley Take Over the World” that Looks like the Russian River Valleyparodies the TTB for entertaining the notion that the Russian River AVA should be enlarged to the south by 550 acres of vineyards. Who would want that done? Well, let’s see; the expansion would give 350 acres belonging to Gallo the right to a Russian River Valley designation on the label. Would the TTB grant such an expansion because the world’s second largest wine producer wanted it? Think of this: The last time the Russian River AVA was expanded, in 2005, it benefited Kendall-Jackson.

All the issues in this matter, with appropriate historical, geographical and climatic background, appeared in a story by Kevin McCallum in the Santa Rosa Press-Democrat on September 11.

If the TTB grants the expansion of the Russian River Valley appellation — and there’s no reason to think that it won’t — the action will serve to emphasize, yet again, that the AVA system is, in some part, meaningless for producers and consumers. According to the AVA guidelines, “We designate viticultural areas to allow vintners to better describe the origins of their wines and to allow consumers to better identify wines they may purchase.” How does that disingenuous expression of good intentions apply to, for example, the North Coast AVA, which encompasses three million acres in Lake, Marin, Mendocino, Napa, Sonoma and Solano counties? ( lists 12 wineries in Solano.) And how does it benefit consumers that the 15,500-acre Dos Rios AVA in Mendocino, approved in November 2005, exists because of one winery, Vin de Tevis, that cultivates six acres of vines? I mean the TTB seems to pass AVAs out like candy — or to the highest bidder.

Of course, many of the AVAs make sense in terms of soil, climate, geography and traditional usage, but those that don’t merely focus our attention on the often ludicrous character of the enterprise and on the political nature of its sometimes dubious accomplishments.

While one might suppose that such issues are managed better in Europe, with its centuries-old heritage of vineyards, small growing and winemaking areas and a pervasive wine culture, one would, to some extent, be wrong.

Oh certainly the communes of Bordeaux and the tiny Grand Cru and Premier Cru vineyards of Burgundy seem irrefutable and secure in the AOC (appellation contrôlée) pantheon and the self-regard of Big Spenders. And it’s gratifying to see, as was recently announced, the addition of a 51st Grand Cru area in Alsace, the 175-acre Kaefferkopf of Ammerschwihr, based on a particular geologic formation, part granite and part limestone, that sets it apart from its neighbors; Kaefferkopf’s elevation to Grand Cru status is also based on a heritage of delimitation going back to 1932. Of course the French being the French and Alsace being Alsace, the percentage of grapes in blending — gewurztraminer, pinot gris and riesling — is prescribed by law. You won’t find that in the Russian River Valley.

On the other hand, the approval of the expansion of Champagne’s vineyard area earlier this year cannot be a harbinger of better quality. The squeeze is on in Champagne, demand is high and prices for grand marques and artisan products are rising, thanks especially to parts of the world — Russia and Asia — where people actually have money to spend. Better to let the situation sort itself out, however painful it might be, than to dilute the reputation of a hallowed region. (Yes, I know, it can be argued that the Grand Marque houses are diluting reputations themselves by overproduction and a certain mechanical aptitude.)

France is also home to one of my favorite bizarre designated wine regions, the Vin de Pays de Méditerranée, a vast area that Looks like the Mediterranean encompasses 10 departments in the lower Rhone Valley, Provence and the island of Corsica, which is, of course, not officially attached to the mainland of France. One appreciates the desire of local cooperatives to band together for solidarity and marketing purposes, but this Vin de Pays seems to be based primarily on a notion of all things romantic and salable conjured by the word “Mediterranean.”

My point is that consumers are far better off educating themselves in what kinds of wine they enjoy most than in depending on the potential quality of an AVA (or any country’s scheme of designation), whether a vast one or one that’s strictly limited. If you’re interested in pinot noir or sauvignon blanc, buy as many as you can afford from different regions and taste them blind, that is with labels concealed. If you consistently like the examples from one region, concentrate on that region, try other wines of the same genre, explore what’s offered in the style of wine that you like. Ask your friendly trusted retailer (or brilliant blogger) for advice in delving more deeply into what’s available. Trust your palate.

Images from and

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