Vineyard & Winery Management

January/February 2014

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continues to emphasize that the purpose of the rule is to enhance consumer protection, and ensure that labels provide consumers sufficient information about the identity and quality of the products they are consuming. According to a letter prepared by the Wine Institute in response to Notice No. 73, many wineries rely on the use of the designation "Table Wine" as permitted under the Federal Alcohol Administration Act, so that they can meet production targets by printing labels in advance. The wine industry will suffer a significant economic impact if labels reflecting the specific alcohol content of every batch are required. (Under the current law, wines with 7%-14% alcohol content need not include the alcohol percentages on their labels.) There are also aesthetic concerns to consider. If the proposed rules become mandatory, some industry members may be forced to change the shape and/or size of their labels entirely to include the Serving Facts panel, which may be detrimental to brand recognition. Finally, the composition of wines is inherently variable with the alcohol and residual sugar levels varying significantly among styles as well as years, regions, etc. It is also common for winemakers to adjust a wine blend to meet a specific style, or maintain consistency within a particular vintage, right up to the time of bottling. Thus, requiring wineries to include a Serving Facts statement that accurately reflects caloric and carbohydrate content on their labels will impose additional severe financial and logistical burdens on the industry. While the formal process for comments and objections to Notice No. 73's potentially mandatory nutrition and alcohol content labeling rules has concluded, industry members can take matters into their own hands by contacting the Regulations and Rulings Division of the TTB and/or their local congressmen to express their concerns. They can also contact industry advocacy groups, such as the Wine Institute and WineAmerica, to find out what they are doing to stop these regulations from going into effect and how they can help. Jordan Ber nstein and Taylor Burras are attorneys in the law firm of Michelman & Robinson LLP, and serve in the firm's Commercial and Business Litigation Department and the Restaurant, Food & Beverage Industry Practice Group. Michelman & Robinson has offices in Los Angeles, Orange County, San Francisco, Sacramento and New York. Bernstein and Burras can be reached at (818)783-5530 or by e-mail at jbernstein@mrllp.com and tburras@mrllp.com. Comments? Please e-mail us at feedback@vwmmedia.com. Products for SO2 and pH/TA Low-cost meters for SO2, pH and TA in wine Vinmetrica's latest additions to its line of products for wine analysis: The SC-100 gives accurate, easy SO2 results The SC-200 is a rugged pH and TA meter The SC-300 measures SO2, pH and TA! From $173 - $352 Assembled in the USA 444 Laguna Vista Rd. Santa Rosa, CA 95401 e-mail: vickitec@aol.com www.transitionequipment.com Tel: (707) 537-7787 Fax: (707) 537-7174 Cell: (707) 484-8776 Specializing in used equipment for wine, beverage & packaging w w w. v w m m e d i a.com pH/TA (SC-200 and SC-300) SO2 (SC-100 and SC-300)* Accuracy: 0.02 pH and 0.1 g/L T.A. Autocalibrate at pH 3, 4, 7, 10 Accurate to 1 ppm Easy-to-use instrument Check our product page at 1945 Camino Vida Roble, Suite I - Carlsbad, CA 92008 (760) 494-0597 J a n - Feb 2014 | V INE YA RD & W INE RY M A NAG EM EN T 145

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