by Courtney Cochran
I feel sorry for those of you who – like me – have been attempting to follow the US Alcohol and Tobacco Trade and Tax Bureau’s controversial proposed amendments to American Viticultural Area (AVA) regulations. I feel sorry for anyone, for that matter, who is sorting through the piles of legalese and angry banter being circulated about the matter in newspapers and online, not only because it's all terrifically confusing, but also because the proposals at the center of the controversy shouldn't even be up for debate at all.
Proposed amendments hinge on a fundamental shift in regulations that would prohibit wines hailing from smaller appellations located or “nested” within larger appellations (e.g. Oakville within Napa Valley) from listing both the sub- and macro-appellations on their labels. Besides this, there are other issues at play in the current mess, most importantly a proposed "grandfather” clause that would allow wineries founded between 1986 and 2005 to continue to use place names that are also appellations in their brand names (e.g. the soon-to-be-approved Calistoga AVA, as in the case of Calistoga Cellars) even though their wines may not satisfy the standard requirement that a minimum of 85% of the grapes used to make a wine be grown in the wine’s stated AVA.
If all this sounds confusing – and WRONG – that’s because it is.When a Spade Isn’t a Spade
When it comes down to it, listing both a sub appellation and a macro appellation – especially when the sub AVA is a new and/or little known region – is a key marketing tool wineries use to communicate what’s inside the bottle. For example, a consumer might hesitate to order a Cabernet Sauvignon from “Wild Horse Valley” (popularly held to be Napa’s least-known AVA) but he or she might decide to give the wine a try if the bottle listed both “Wild Horse Valley” and “Napa Valley” on its label.
As recognition of the Wild Horse Valley AVA and its wines grows, that indication on a bottle may very well become a source of differentiation that helps vintners from the area to sell their wines. And while we're on the subject, differentiation is also the key economic driver that allows producers to charge more for their products than others charge for similar, undifferentiated products. So, the most effectively differentiated products are not only more likely to sell, they’re more likely to sell at a higher price.
And don’t even get me started on what’s wrong with a wine’s inferring it comes from a certain place when, in fact, the legal threshold for grapes coming from that region hasn’t been met.At What Cost Costs?
Rumor has it that the Alcohol and Tobacco Trade and Tax Bureau (TTB) proposed these amendments as a result of the growing number of sub AVA petitions the bureau is receiving and the its members’ desire to manage costs associated with processing the petitions and regulating wine labels that list an increasingly large number of regions. The problem is, we need to look beyond these superficial costs. Restricting geographic labeling can only hurt wineries and therefore – on a much larger scale – hobble the wine industry itself, one of California’s most vibrant and economically viable agricultural entities. Moreover, I seriously doubt that the costs “saved” by TTB could equal the long-term fiscal impact of these changes on the industry.
As a sommelier I will always be in support of providing consumers with the most information possible about a wine – and in this case that means both sub and macro AVA identification. And I will always press for veracity in wine labeling.
For these reasons, I find the changes proposed by the TTB unacceptable and in need of review. At the end of the day, refuting TTB’s proposals and maintaining or more fairly altering the current AVA regulation policies will only help winemakers - folks who for the most part make wine with integrity and would also like to market their wines with integrity – not to mention sell a good amount of the stuff while they’re at it.
To voice your own opinion on the subject, visit Docket No. TTB-2007-0068 at www.regulations.gov