We joke a lot about cutesy wine labels with koala bears on them, but wine labeling is serious business. The Alcohol and Tobacco Tax and Trade Bureau (TTB), part of the Treasury Department, is responsible for enforcing alcohol labeling requirements mandated by law. Believe it or not, the labels on every bottle of wine sold in the U.S. have gone through the TTB approval process. Since we’re bringing on some new producers, we’re discussing the ins and outs of U.S. labeling requirements with them, and I thought you might like to know just what wine labels are all about.
As long as you have all the required information on the back label, you can pretty much put what you like on the front, as long as it's not false advertising...
Most wine bottles have two labels on them. Two aren’t required, but getting all the mandated information on one label and making it distinctive and beautiful is tough work. Jokes about the koala aside, many people are swayed on a choice between two wines by which one has the better looking front label. So a simple, beautiful front label with very little text means there’s a back label that tells you what the U.S. government wants you to know about your wine. And the print can’t be too small, either (something I’m beginning to appreciate when I have to reach for my reading glasses!)
There are nine required pieces of information on wine labels:
1) Brand name – the name under which the wine is marketed. This may or may not be the manufacturer or owner, since a brand name can be a subsidiary of another. You won’t find the name “Gallo” on Barefoot wines, for example, even though that’s who owns them.
2) Class/type – the specific identity of the wine, such as Red Rhône Wine, Sauvignon Blanc, etc. If the class or type is a specific varietal name, the name must be rendered in letters no smaller than 2 mm. Believe it or not, there is no requirement to tell you what grapes are in any wine. They can simply be labeled as “Red Table Wine” or “White Table Wine,” without any additional information. However, if the wine is labeled as “Sauvignon Blanc,” that means that 75% or more of the grapes used in the wine must be Sauvignon Blanc. If more than one grape is listed, then they all have to be there, with percentages, totaling 100% of the grapes used in the wine.
This probably passes muster for truth in advertising.
3) Alcohol content – generally listed as Alc xx% by volume, or as a range. The lettering used for the alcohol content must be between 2 and 3 mm in height.
4) Appellation of origin – the region or place where the grapes for the wine are grown. The location has to have a specific designation recognized by the U.S. Government, such as Cotes du Rhône, Vin de Pays d’Oc, Napa Valley, etc. This is not a static list. When I started submitting First Vine labels to TTB, TTB didn’t recognize Vinsobres as an appellation (even though the French AOC authorities did). I had to contact the trade representatives at the French Embassy here in DC, and they had to pester the DC-based EU trade reps to update the EU list of French appellations and get it over to TTB. And it’s not just in France — lately there has also been a dust-up over just what can be called “Napa” or not.
5) Name and address – the city and state of the bottler (for U.S. wines) or importer (for imported wines). These must be written in a font size no smaller than 2 mm.
6) Net contents – the amount of wine in the bottle, always in metric units (750 ml, 1.5 L, etc). Distilled spirits are also listed in metric units. Interestingly, malt beverage net contents must be in American units, which is why most cans and bottles of American beer are listed as containing 12 ounces, and foreign beers are listed first in ounces and then in metric units. Instead of appearing on the label, the net contents may also be blown or branded into the bottle to meet this requirement.
7) Sulfite statement – if the wine contains 10 or more parts per million of sulfites, whether there are any added sulfites or not, the label must say Contains Sulfites. This information is provided because some people with severe respiratory conditions are ultra-sensitive to sulfites. (As we’ve discussed before, most people aren’t really allergic to sulfites, even if they think they are).
8) Country of origin – required by U.S. Customs for imported wine. The origin statement must be worded as Product of France for French wines.
9) Government warning – this is the health warning you see on each bottle of wine, malt beverages, and distilled spirits. It must be completely legible and worded exactly as required by law, in a font size no smaller than 2 mm, and separated by other text by at least 2 mm on all sides (for a standard 750 ml wine bottle). The opening words, GOVERNMENT WARNING must appear in capital letters and in type that is bolder than the rest of the warning statement. Here is the full text:
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.
It really does look like a warning against becoming pregnant, doesn't it? I mean, you can't really see that she's holding a glass -- she could just be giving someone the finger!
TTB will not allow any other health warning to appear on a bottle of wine, even if that warning is required by the country where the wine was made. In France, for example, new labeling laws require a symbol to show that pregnant women shouldn’t drink alcohol. It doesn’t seem terribly subversive (in fact, it looks more like a warning against pregnancy itself rather than drinking while pregnant), but TTB will not approve labels with the pregnancy symbol on them. We submitted a label to TTB without realizing the symbol was there and was the label was indeed rejected. Lots of photoshopping and frantic e-mails to the producer later, and we had a symbol-free label that passed muster with TTB.
A fabulous back label for a fabulous wine! (Click on it to enlarge)
As importers, we’re responsible for making sure that the wine we import has approved labels. Since we were working with producers who hadn’t exported before, we wanted to design a back label from scratch that would contain all the necessary information and give you some things you could use. Along with the grapes in the wine (always useful to know), we recommend a serving temperature. Many people serve their white wines too cold and their reds too warm. Five degrees can make a huge difference in flavor, so we want you to experience these wines at their best. We’ve also recommended some food pairings for the wines. Finally, we try to let you know how long you should keep them around before they won’t be quite as vibrant as they were when you bought them. All in a space that’s three by three-and-a-half inches! Such a deal! And now, the recipe. To celebrate the opening of the wine bar at ACKC (1429 14th St. NW, serving wine from 5 pm until closing daily – you didn’t think I was going to let an opportunity to mention it go by, did you?) I bought myself a great new cookbook –The Bacon Cookbook by James Villas. Really, what’s not to love about 150 recipes using bacon in all its glorious forms? I was tempted to give you his recipe for Japanese Bacon Tempura – literally battered and deep-fried bacon – but even I have my limits!One of Villas’s specialties is French cooking, and the bacon book includes a recipe for Quiche Lorraine with the traditional pastry crust. Coincidentally, a couple of nights ago, I was watching an episode of “Sarah’s Weeknight Meals” on PBS (a great show with Sarah Moulton, the only TV chef skilled enough to answer live questions on the air as she cooked. Forget that crackpot “Ask Aida” on the Food Network, who can’t even read cue cards without seeming rehearsed) and she made a quiche with a cracker crust. It never occurred to me to make a cracker crust for quiche, but what a great way to make it simpler without resorting to an icky pre-made crust! So here’s a recipe that combines the best of both. Villas reminds us that the original Quiche Lorraine was just cream, eggs, and bacon, but I think a little Gruyere cheese and onion are a great addition.
And what to serve? Our fabulous Château Milon Bordeaux Supérieur Rouge ($21), of course! We can’t let that fabulous label go unnoticed, can we?
Bon Appetit!
Tom
“Weeknight” Quiche Lorraine with a Cracker Crust
Makes 8 slices, 4 to 6 servings
Crust
24 whole grain crackers (like low-sodium Triscuits), ground in a food processor (about 1 cup)
4 tablespoons melted butter
Preheat the oven to 375 degrees F. Combine the butter and cracker crumbs and spread in the bottom and one inch up the sides of a 9-inch pyrex pie plate. Bake the crust for 7 minutes and remove it from the oven.
Filling
½ pound sliced lean-ish smoked bacon, cut crosswise into half-inch pieces
1 small onion, cut in half through the poles, then sliced thinly
½ cup grated Gruyere or Swiss cheese
1-1/2 cups heavy cream
3 large eggs
Salt and freshly-ground black pepper
Pinch of grated nutmeg
Saute the bacon over medium heat in a large skillet until browned. Remove the bacon from the skillet with a slotted spoon and let it drain on paper towels. When drained, sprinkle the bacon evenly over the bottom of the partially-baked crust. Pour off all but about a tablespoon of fat from the skillet and sauté the onion for about 10 minutes, until lightly browned. Sprinkle the onion over the bacon, then the Gruyere cheese. In a medium bowl, beat the eggs and cream, add the nutmeg, then a little pepper and salt. Pour carefully into the prepared crust and then bake about 40 minutes until the filling is set and the quiche is a little puffy and golden. Let it cool for about 10 minutes, then serve.
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