CHARTRAND IMPORTS
P.O. Box 1319, Rockland, Maine 04841
Tel. (207) 594-7300, (800) 473-7307
email: [email protected]
P.O. Box 1319, Rockland, Maine 04841
Tel. (207) 594-7300, (800) 473-7307
email: [email protected]
The USDA Proposed Rules will have drastic unintended consequences for the growing and sales of organic wine grapes in the US and abroad. In contrast to the earlier proposed rules and more recent NOSB recommendations, the current text would not allow any wine made from organic grapes that contains added sulfur dioxide (SO2) to be labeled as either "organic wine" or "wine from organic grapes".
The last proposed rule allowed wine from organic grapes with added SO2 under 100ppm total sulfites to be labeled as "organic wine", which had been recommended by NOSB in 1995 at the Orlando meeting. In 1998, NOSB revised their recommendation to only allow wine from organic grapes with no added SO2 to be labeled "organic wine". Wines containing under 100ppm total sulfites from added SO2 would be allowed the label "wine from organic grapes". The Organic Trade Association's American Organic Standards followed this recommendation in 1999. The recent USDA Rule completely ignores and negates years of study and debate within the organic industry on this issue that resulted in prior NOSB positions.
We estimate that at least 80% of the wines made from organic grapes in the US are bottled with added sulfur dioxide. In any other wine producing country this figure would be above 98%. Since the USDA Organic Program began, the Bureau of Alcohol, Tobacco, and Firearms (BATF) has only allowed use of the term "wine from organic grapes" on any wine label submitted with or without added SO2 as long as organic certification of the grapes was documented. European Community organic standards also allow wines from organic grapes to be so labeled regardless of use of SO2. A growing number of US organic wines are exported to the EEC with the "made from organic grapes" label and hundreds of foreign wines are now imported into the US with the same designation.
Sulfur in some form has been used in winemaking for centuries and probably dates back to the Greco-Roman period when its cleansing properties were widely known. In addition to its anti-bacterial action, sulfur retards oxidation in wines. This inevitable process causes browning and loss of flavor particularly in white or rose wines. Sulfur dioxide binds loose oxygen molecules, reducing and delaying for years the oxidation. It is usually added to wine before bottling in a gaseous or diluted form. If winemakers use this natural form rather than synthetic potassium metabisulfites, they are not actually adding sulfites to the product. Sulfites are formed in the wine when added sulfur dioxide reacts with water in the wine. In addition, amounts of completely natural sulfites are created in wine during fermentation through changes to sulfates existing in grapes The prohibition in the Organic Foods Production Act (OFPA) specifically rejects "added sulfites" NOT added sulfur dioxide. In addition, sulfur is allowed in organic agricultural use for anti-fungal applications.
By any standard in the OFPA, sulfur dioxide should be allowed in organic wines. Sulfur dioxide is not harmful to the environment or to human health, and it is necessary to production of any commercially viable quantities of high quality wine. Wine is not a product that can be sold within a month or two of bottling. It simply is not possible given the public expectations of wine stability and the current distribution system, and is not desirable for wine quality. The only drawback to this irreplaceable additive is the allergenic nature for about 4% of the population. The FDA acted to protect this population in 1988 when all foods containing sulfites were required to show clear and visible warnings such as "Contains Sulfites". Since that time all organic wines have shown this warning and our industry has used significant resources in educating our customers to the fact that some organic wines have added sulfur and some do not. Some organic pretzels have added salt and some do not, but the customers do not believe that one is more organic than the other. Our customers also have come to this understanding since all wines with over 10ppm total SO2 show the mandatory warning label. Those allergic to sulfur seek out the organic wines without added SO2, and other customers have a wider choice of organic wines, including all imports that require a longer time from winery to shelf.
Although some winemakers began making wine without added SO2 after mandatory sulfite warning were required, none did before that time. The entry of these no added sulfite wines into the marketplace brought along greater rates of spoilage and more questionable quality in organic wines. As an industry, we have struggled for years to correct the perception that "organic wines taste bad and don't keep well" that was in large part based on trials of organic wines without added SO2. Customers seeking organic wines without added SO2 now know that they risk buying a fragile wine, while the majority of buyers seek a more stable product that nonetheless gives them the guarantee of certified organic grapes and all the consequent value involved in that choice.
Most organic wines in fact contain NO other ingredient than organic grapes and a maximum 80ppm or less than .0001% of total sulfites from both added SO2 and natural sulfates. How can we not tell our customers that this wine from 99.999% organic grapes is in fact "made from organic grapes", when many other foods with only 50% organic ingredients will be touting their "organic" composition? Organic wines are being held to a standard more strict than any other commodity. How can we expect a vineyard to continue certification when they will not even be able to tell the simple truth of grape origin to the customer? Wine grapes have had the most certified acreage of any organic crop in CA for several years, although total acreage has dropped recently, with continued lack of clarity on organic standards and their effect on grape sales. This ruling would devastate the sales of certified grapes, since the majority of wineries making wine from these grapes use SO2 and will not pay a premium for organic grapes without the privilege of informing customers of this quality.
In addition to the effect on organic grape growing in the US, the rule would severely limit sales of US organic wines worldwide, as our standards would not even allow producers to mention organic grapes on the label, in complete contrast to other worldwide agreements. In addition foreign producers would lose hundreds of products currently sold in the US according to the existing rule that allows "made from...". The ability of BATF to enforce this rule would also be a challenge, since thousands of labels are already approved using the "wine from organic grapes" statement.
Although there are still consumers who do not understand the use of or origin of SO2 in wine, and they may sincerely prefer to not have "organic wine" with any added sulfur, the OFPA is not supposed to increase public misperceptions at the expense of organic agriculture. Part of the role of USDA and the organic industry is to educate the public about organic foods and appropriate expectations for their processing and quality. The advantages to our quality of life from a wine from organic grapes far exceed any question of added sulfites or the lack of them.
The inclusion of a prohibition on sulfites and two other substances in the original OFPA was an aberration from the intent and form of the Act, since use of all other substances is to be decided through a fair and comprehensive evaluation process. Whatever decision led to this OFPA wording inevitably bypassed any reasoned dialogue on usage of these additives. All other foods and their requisite processing aids were allowed a full hearing before NOSB and USDA. The organic wine grape industry has struggled with this clause for almost ten years and arrived at a fair resolution with recent NOSB suggestions. To now reverse this process and risk the loss of this entire segment of the organic industry is unacceptable.
