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Nutritious, Vitamin Wine

This deftly navigates the differences between FDA and TTB rules. If it had a little more alcohol, or a different type of alcohol, at least these 5 noted things probably would not fly.

  1. So far as we know, TTB does not allow electrolyte references on alcohol beverage labels.
  2. Nor does TTB allow vitamin references.
  3. From time to time in the past TTB has frowned upon prominent refresh claims on the grounds that they may imply therapeutic value.
  4. As of this writing it does not appear that TTB is ok with GMO claims.
  5. Finally, I would bet money against TTB allowing this term (nutritious).

All these claims are possible, and not suicidal, because the product is wine based, and under 7% alc./vol., such that FDA has full control over the labeling, while TTB retains control of the taxation and formula. The front label mentions that it’s a wine specialty, as here.

If this were 7% or more, TTB would probably require something a lot more descriptive than “Wine Specialty,” and would not allow this 12 ounce size, and would also require ABV to be spelled out. The product is Coco Cocktail, and there is no TTB label approval to which to point.

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Hillary on a Wine Label; Donald on Beer

With only two days to go until the second Presidential Debate, Trump and Clinton are clearly on everyone’s mind. Including the beer and wine companies shown above.

The Trump-inspired Blonde Ale label is from 5 Rabbit Cerveceria of Bedford Park, Illinois. It leaves no doubt they are not Trump fans. It says: “STOP THE HATE,” “CHINGA TU PELO” (look it up), “We decided to take a stand against racism,” “BULLIES AREN’T LEADERS.” Frank would love to have a can of this in time for the big event.

The Clinton-inspired Chardonnay label is from Scotto Family Cellars of Lodi, California. They have a couple types, and six approvals. We did not find any Trump-related labels at this company. Perhaps it would infringe on this.

Both seem to be real products and TTB apparently approves of both messages.

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Bourbon-Barrel-Aged Wine

bzin

At USBevX a few days ago I heard lots of questions about various wines aged in Bourbon barrels. But I did not hear lots of answers so I thought I would take a look and see what’s going on. This Fetzer example, above, seems like a good place to start.

It tends to show that it is okay to mention Bourbon on a vintage- and varietal-designated wine. I am a little surprised I don’t see any reference to a formula approval, or to the amount of aging in said barrel. This Fetzer label is also noteworthy because it quickly drew the ire of the big Buffalo, as in Buffalo Trace; Sazerac charged at Fetzer for attempting to graze on land staked out long ago by the whiskey company. This really good article discusses the trademark dispute, about 1/3 of the way down the page.

I see about 64 wine labels with reference to Bourbon as approved by TTB during the past five years. Another representative one, from another big company, is this Robert Mondavi approval. I don’t really see any comparable labels, in the prior five year period. From these two examples, and a bit of asking around, it sounds like the reference to Bourbon should not appear on the same line as the wine’s class/type statement. Also, you are more likely to need aging details (e.g., Aged 6 Months) on the label if the age reference appears on the “brand label.”

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whisky, wine


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Wine Growlers

growlerEnvironmentally-conscious and corkscrew-phobic wine lovers alike will be thrilled to hear that TTB issued a ruling on March 11, 2014, allowing the filling of wine growlers by TTB-licensed tax-paid wine bottling houses (“TPWBH”). The ruling is in response to a new Washington state law allowing state-licensed wineries to sell wine off-site in kegs or “sanitary containers” (i.e., growlers) for off-premise consumption. Oregon passed a similar law in April 2013.

These laws are particularly helpful to wineries that operate both a production facility and a separate tasting room, allowing them to fill growlers for off-premise consumption at either location. The TTB ruling is somewhat less helpful to wine retailers, requiring that they go to the extra trouble of becoming TPWBH-licensed and comply with label and recordkeeping requirements.

Some wine retailers complain that it is unfair to not allow non-TPBH wine shops to sell growler fills to-go, since beer shops currently enjoy that privilege. TTB explains, the Internal Revenue Code (“IRC”) “has very specific requirements regarding the bottling of taxpaid wine. Section 5352 of the IRC requires any person who bottles, packages, or repackages taxpaid wine to first apply for and receive permission to operate as a taxpaid wine bottling house. There is no analogous provision with respect to beer.” The current TTB ruling interprets growler filling as bottling or packing and, therefore, restricted to TPWBH-licensed vendors.

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Is Wine Vegan?

Not that I read the PETA stuff every day, but I could not resist when I stumbled on PETA’s article entitled, “Is Wine Vegan?” It makes the point that:

The majority of people are unaware that wine, although made from grapes, may have been made using animal-derived products. During the winemaking process, the liquid is filtered through substances called “fining agents.” This process is used to remove protein, yeast, cloudiness, “off” flavors and colorings, and other organic particles. Popular animal-derived fining agents used in the production of wine include blood and bone marrow, casein (milk protein), chitin (fiber from crustacean shells), egg albumen (derived from egg whites), fish oil, gelatin (protein from boiling animal parts), and isinglass (gelatin from fish bladder membranes). Thankfully, there are several common fining agents that are animal-friendly and used to make vegan wine. Carbon, bentonite clay, limestone, kaolin clay, plant casein, silica gel, and vegetable plaques are all suitable alternatives.

For those who would prefer not to torment an animal in the course of pouring a glass of wine, The Vegan Wine Guide already lists more than 400 wines. The Vegan Vine seems like a good example. As I flipped through a few of the 400, I was not surprised to see that few if any make direct claims that the wine qualifies as “vegan.” After all, TTB is not known for being footloose and fancy-free about various claims. Foursight Wines has said:

[we were] pleased that the TTB allowed us to state that our wines are suitable for vegetarian and vegan diets. Clos La Chance has begun marketing all vegan wines, but the TTB didn’t allow them to say that the wines didn’t use animal products (see the Wines & Vines article here). Frey is a noted vegan producer but their wines don’t list it on the label. So, unless anyone out there has a correction for me, I have yet to find another U.S. producer with a vegan and vegetarian statement on their wine labels.

If your tastes run in the other direction, you may prefer these libations replete with animal byproducts.

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