OTB # 11 –Not So Fine Print –Part 1 of…more than 1

When you look at a wine bottle, what do you see? The shape, color or weight of the glass, the type of cork or closure, or the graphic art on the label? All of these things matter, but the things that interest me most are the words written or printed on the label(s). Here in the U.S. there are certain required words that we’re all familiar with, don’t drink and drive or become pregnant while driving a tractor. Or something like that.

Other required elements include the name of winery, sulfites (if contained), percent alcohol (if over 14%), and a few other things. The one in particular that is most interesting to me as a fanatic of Washington wine and its wine regions is the origin of the grapes used in the wine, or appellation.

The rule itself is easy to find, if not exactly clear, and is located in the Code of Federal Regulations at Title 47 CFR Section 4.25 Appellation of Origin. Since I’m only interested in U.S. wines, mainly those from Washington and its AVA’s I’ve culled this down to the relevant regs:

 

(1) American wine. An American appellation of origin is: (i) The United States; (ii) a State; (iii) two or no more than three States which are all contiguous; (iv) a county (which must be identified with the word “county”, in the same size of type, and in letters as conspicuous as the name of the county); (v) two or no more than three counties in the same States; or (vi) a viticultural area (as defined in paragraph (e) of this section).

e) Viticultural area —(1) Definition —(i) American wine. A delimited grape growing region distinguishable by geographical features, the boundaries of which have been recognized and defined in part 9 of this chapter.

(2) Establishment of American viticultural areas. Petitions for establishment of American viticultural areas may be made to the Administrator by any interested party, pursuant to the provisions of §70.701(c) of this title. The petition may be in the form of a letter, and should contain the following information referred to in §9.3(b) of this title.

(3) Requirements for use. A wine may be labeled with a viticultural area appellation if:

(i) The appellation has been approved under part 9 of this title or by the appropriate foreign government;

(ii) Not less than 85 percent of the wine is derived from grapes grown within the boundaries of the viticultural area;

(iv) In the case of American wine, it has been fully finished within the State, or one of the States, within which the labeled viticultural area is located (except for cellar treatment pursuant to §4.22(c), and blending which does not result in an alteration of class and type under §4.22(b)).

(4) Overlap viticultural area appellations. An appellation of origin comprised of more than one viticultural area may be used in the case of overlapping viticultural areas if not less than 85 percent of the volume of the wine is derived from grapes grown in the overlapping area.

I spend part of my time every day reading federal and state regulations (sounds fun, huhnh?), so this stuff is pretty familiar to me. The important parts are always the verbs and the definitions. I’m not a lawyer, but I heard one say that some time. As an aside, the parts of the CFR now being written like Jeopardy answers and questions are pretty silly as well as impossible to understand.

Anyway, the most important word in this whole regulation is the word “may” under (3) Requirements of Use. It’s not really a requirement unless the rules say shall or must. And it becomes important when wineries, particularly those in Washington, decide what to claim as the origin of their wine. I’ll eventually try to explain why I think this.

The definitions include American Viticultrual Areas, or AVA’s. How to become one and where they are is defined elsewhere, but for Washington State there are 11 currently federally approved AVA’s. One of them, Puget Sound, is a straight forward stand alone AVA, a few stray down into Oregon (The Shame!), and the most tricky part (and the one I’m becoming obsessed with to the point this post and the next couple might ramble and become a little ranty) is the fact that Washington’s Eastern AVA’s are embedded and overlapping and are essentially a third grade math lesson on sets and subsets.

Here’s what I mean. The vast majority of Washington’s grapes are grown in the Columbia Valley AVA; the Puget Sound and Columbia Gorge AVA’s are the only outside ths “umbrella” AVA. Inside the Columbia Valley (north to south, west to east) are a subset Lake Chelan, Wahluke Slope, Yakima Valley, Horse Heaven Hills, and Walla Walla Valley. Then more subsetting, inside Yakima Valley are Rattlesnake Hills, Red Mountain, and, as of 2009, Snipes Mountain.

 

The map is pretty helpful if you have a microscope to find Lake Chelan, Snipes, and Red Mountain.  It might look like this (using CFR numbering but refusing to not indent like the asinine regulations) :

a. Puget Sound

b. Columbia Gorge

c. Columbia Valley

       1. Lake Chelan

       2. Wahluke Slope

       3. Yakima Valley

                i. Rattlesnake Hills

                ii. Red Mountain

                iii. Snipes Mountain

       4. Horse Heaven Hills

       5. Walla Walla Valley

One of the things that affects labelling too is when these AVA’s are established, particularly since many of  these in Washington are pretty much brand spanking new designations and wines sometimes take several years to go from vine to shelf.   Label approval and slapping them on the bottle before they get sold is sometimes a slow process too.  Here are the dates each of Washington’s AVA’s became approved by the TTB.

Yakima Valley – 1983

Columbia Valley – 1984

Walla Walla Valley – 1984

Puget Sound – 1995

Red Mountain – 2001

Columbia Gorge – 2004

Horse Heaven Hills – 2005

Wahluke Slope – 2006

Rattlesnake Hills – 2006

Lake Chelan – 2009

Snipes Mountain – 2009

As you can see, just in the last decade the number has gone from four to eleven, and the newest AVA’s have technically just picked one crop of grapes from the designated AVA, though labelling of prior years from an approved area is allowed since I’ve seen (and written about) at least one 2007 vintage Snipes Mountain label. 

There are various petitions pending for further subdivisions of the Columbia Valley, and maybe the Yakima and Walla Walla Valleys, too. I don’t know if the third generation AVA’s, Rattlesnake, Snipes, and Red Mountain, will ever subdivide, but anything’s possible if a geologist uncovers another type of soil or a marketing person perceives another advantage.

What does marketing have to do with the concept of terroir and sciences of geology, meteorology and sun angles? Only everything.

This post has been calm and boring and I’ve tried to explain regulations on appelation labelling and the subsets of Washington AVA’s in a manner that makes sense. Next time I’ll try to understand the human emotions of pride, prestige, and perception as they play into what the two or three (or twenty) words on a wine label describing appellation of origin mean. Stay tuned.

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OTB Fun Fact: This week is the 30th Anniversary of the cataclysmic eruption of Mount St. Helen’s. You know you’re old when half of your friends and co-workers give you a blank look when you ask them where they were when something historic like this happened. For the record, I was in high school in Tennessee and remember watching this on the news during the weeks leading up to the Big Bang, and being amazed at the Bang itself. Much more impressive than anything Hollywood has ever tried to create, even Star Wars.  The Empire Strikes Back was released to theatres three days after Helen blew her top.