The TTB published an interim rule, T.D. TTB-53, 71 FR 42260, effective on July 26, 2006, which sets forth standards for optional allergen labeling statements. “This is still the official statement from the TTB,” Dr. Trela points out. “There has been no date offered for implementation, other than indications that ultimately there will be mandatory allergen disclosure requirements in the U.S. for all alcoholic beverages.”
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FSMA will affect wine production, Dr. Trela notes. Actually, it already has. During fiscal years 2009-2012, about 393 FSMA winery inspections were conducted nationwide.
“While the FDA has always had inspection authority over wineries, many of the 2011 FSMA provisions do not apply to wineries,” Dr. Trela says. “However, there are instances where they may be invoked and compliance with the entire Act is required through Section 116: a) distribute an unpackaged or repackaged (e.g. potentially exposed to direct human contact), non-alcohol food item; or b) sell prepackaged food in an amount greater than 5 percent of the overall facility sales. The FDA sought public comment on the rules and potential impacts of the FSMA on wineries that concluded in November 2013. Further regulations or changes to the regulations are expected to follow.”
FSMA states that all food facilities must be inspected within seven years and at least once every five years after that.
“The FDA may contract state agencies to conduct winery inspections,” Dr. Trela says. “The FSMA directs the FDA, under the federal Bioterrorism Act, to inspect every registered food facility, including wineries, in the U.S. by 2018. Due to the recognized relatively low food safety risk of wines, the FDA may scrutinize wineries less than most other food facilities. Subsequent inspection frequency may likely be based on risk assessments and facility compliance history.”
Leake is a food safety consultant, auditor, and award-winning journalist based in Wilmington, N.C. Reach her at LLLeake@aol.com.
Wine Labeling: Alcohol and Tobacco Tax and Trade Bureau Requirements
According to 27 CFR 4.62, the mandatory information for wine labels includes:
- Front Label: Brand name, class and/or type, alcohol statement (as a % by Vol., or wineries can use “Table Wine” or “Light Wine” if alcohol content is 7% to 14%); appellation of origin, as required in various cases (appellation is mandatory if type, vintage date, or the term ‘estate’ is used).
- Anywhere on the bottle must be the government warning, sulfites statement, bottling statement (name and address of the bottling winery, preceded by certain words such as bottled by, vinted, cellared, etc.), and net contents.
- Class: “grape,” “table,” “light,” “white,” “red,” “pink,” “amber,” “rose,” or “dessert” followed by the word “wine” may be used.
- Type: 75% grape variety, such as “merlot.” (Or various generic, semi-generic, or non-generic information of geographic significance).
- Multiple varietals can be a type designation, but require listing on the label in order of highest to lowest corresponding concentrations, and the total must equal 100%.
- Formula wines are wines that require formula approval, such as agricultural wine (rhubarb), other than standard wine (mixing wine from different classes), flavored wine, non-beverage wine, and high fermentation wine.
- U.S. wine labels do not have to specify the variety. They can have fanciful names and be blends, such as “meritage.” If the wine label has a fanciful name, then that name cannot appear on the same line as the class/type, etc.
For more information go to www.ttb.gov/labeling. —L.L