Organic Wine Label Claims - Tilth's wine expert explains all
by Gwendolyn Wyard
What? Not organic? But it says “Made with Organic Grapes” right there!
You’re standing in a wine shop with a short list of wine to buy for a dinner party on Saturday night. The pick is the Organic Pinot Noir requested by the party host who has sensitivities to sulfites. In one hand, you’re holding a wine that claims “Organic Pinot Noir” on the front panel. In your other hand, you’re holding a wine that claims “Made with Organic Grapes.” What’s the difference? Which one should you choose?
As the resident wine expert at Oregon Tilth, I frequently receive questions regarding the organic regulations governing these two label claims. Even though the National Organic Program (NOP) regulations were implemented almost four years ago, the confusion between the two holds strong. So, here is the official scoop on the difference between an “organic” wine and a “made with organic grapes” wine.
For wines made in 2003 or after, the wine label cannot make an organic claim of any kind on the Principal Display Panel (PDP) unless the wine is certified to the NOP standards by an accredited certifying agency. If the operation makes $5,000 or less on gross organic sales, it is exempt from certification. The certification requirement for non-exempt operations is a change from the pre-NOP years when a wine maker could label their wine “made with organic grapes” and only the grapes had to be certified. Now, in order to make an organic claim (“made with organic grapes” included) on the PDP, both the vineyard and the winery must be certified. If you see a wine label (2003 vintage or after) with any organic claim on the PDP, you should be able to look on the information panel and find a certifier statement identifying the agent that certified the handler of the finished product, i.e. “Certified organic by (specified certifier).” If not, then you are likely looking at a non-compliant product and it should be reported to your local retailer, certifier or the compliance branch of the NOP.
What does each claim represent ?
In short, “organic” wine contains at least 95 percent organic ingredients from certified operations. Added sulfites are not allowed. “Made with Organic Grapes” wine contains at least 70 percent organic ingredients. Sulfites may be added so long as they do not exceed 100 parts per million (ppm) total sulfites. Ok, let’s break this down into parts. Sulfites are used in wine as a preservative for their antimicrobial and antioxidant properties.
Aside from the sulfite issue, the following composition requirements apply to all organic malt and liquor beverages!
Congress passed the Organic Foods Productions Act (OFPA) in the 1990 Farm Bill. Part of its purpose was to establish national standards governing the marketing of certain agricultural products as organically produced products. The regulations located in 7 CFR (Code of Federal Regulations) 205 covering the labeling and marketing of organic wine in the United States are based on OFPA. Section 6510 (a)(s) of OFPA prohibits the use of sulfites, nitrates, or nitrites in the handling of organic products. Thus, during the years of establishing the NOP, the commonly referred to “sulfite wars” occurred. Many people said that sulfites should not be allowed in any certified product. Others said, “but how will we make quality wine?”
In the end, the compromise was to make an exception for wine only and list sulfites under § 205.605(b) of the National List. This section of the National List provides the non-agricultural non-organic substances allowed as ingredients in or on processed products labeled as “organic” or “made with organic (specified ingredients or food group(s)).”
Sulfites are listed as follows:
§ 205.605 (b) Sulfur Dioxide - for use only in wine labeled as “made with organic grapes,” Provided. That, total sulfite concentration does not exceed 100 ppm.
It’s important to note the following details which are not clearly conveyed in the sulfur dioxide annotation: 1) the only form allowed is sulfur dioxide gas – i.e. potassium metabisulfite is not an allowed form; 2) the 100 ppm level is the total sulfites measured at the time of final bottling; 3) naturally occurring sulfites are allowed in organic wine. Tobacco Tax and Trade Bureau (TTB) labeling requirements requires wine labels to list “contains sulfites” if they exceed 10 ppm. Now, with the sulfite requirements in place, let’s take a closer look at the composition requirements.
Organic (95 percent+) wine allows for five percent non-organic ingredients, only when organic agricultural ingredients are not available. Organic and non-org-anic ingredients of the same form may not be used. Non-agricultural non-organic ingredients must be listed on § 205.605 of the National List. Examples of allowed ingredients listed under § 205.605 are yeast, bentonite, diatomaceous earth, and potassium bitartrate. The USDA seal and/or certifier logo may be used on the label, but they are not required. The certifier statement is required on the information panel as mentioned earlier.
“Made with organic grapes” wine allows for 30 percent non-organic ingredients. Agricultural ingredients may be non-organic when they are available in organic form. Non-agricultural non-organic ingredients must be listed on § 205.605 of the National List, same as “organic” wine. The USDA seal is not allowed. The certifier’s logo is optional. The certifier statement is required. Most if not all of the “made with” wine products you will find on the market are made using all organic grapes and would meet the 95 percent organic category if it weren’t for the use of sulfites. In both categories, the product must be handled in accordance with the handling requirements set forth under § 205.270 of the rule which includes requirements for pest management, contamination and commingling prevention, labeling and record keeping.
The last category to mention is the wine label that does not make an organic claim on the PDP of the wine label, but rather on the information panel. This wine does not have to be certified as long as the organic claim is limited to an ingredient statement and there is no reference to certification or any certification agent (name or seal) made. However, unlike most organic food products, an ingredient statement is not required on alcohol products, so its use is somewhat of an oddity. Regardless, this kind of claim on the information panel is one way for a winemaker to tell consumers that organic grapes are used while not having to be certified. While exempt from certification, they are not however, exempt from the NOP record keeping and commingling and contamination prevention requirements. Additionally, TTB will not approve labels making an ingredient statement claim without submission of the organic certificate supporting the claim.
There you have it!
The pick for Saturday night’s dinner party should be the Organic Pinot Noir. While the organic wine will contain small amounts of naturally occurring sulfites that are produced as a fermentation by-product, most people can drink this wine without negative results, moderation being the key. If sulfites are not a concern, then purchase a “made with organic grapes” wine knowing that it was produced and handled in accordance to NOP regulations very similar to the organic wine. If you want assurance that the “made with” wine contains all organic grapes, call up the winery and ask!
Finally, pour, sniff, sip and enjoy. Cheers!
Gwendolyn Wyard is Oregon Tilth’s Processing Program Reviewer and resident wine specialist. She holds a degree in Fermentation Science from Oregon State University.