Monday, April 4, 2016

TTB responds faster to the quest for accurate alcohol labeling

It took 2 1/2 months for my initial query to the TTB about inaccurate alcohol levels on wine labels to get a form letter response. But a followup took only five days, which might set some sort of government speed record.

I don't want to get overly excited here: it's not like the U.S government is suddenly changing its policy on wine labels to no longer be less accurate than most of the civilized world. But the response I got this morning from the Alcohol and Tobacco Tax and Trade Bureau (TTB) came directly to my email, and appears to have been written by a person, rather than cut and pasted from a menu.

The background: U.S. law currently allows the alcohol percentage on a wine label to be inaccurate by as much as 1.5%. The EU and Argentina require the label to be accurate within 0.5%. Obviously this is better for consumers: we want to know how much alcohol we're drinking. You can read my initial letter to the TTB here, and the initial response I received here.

Will the TTB take my request seriously? We can't rule out the possibility. It is the TTB's job to regulate alcohol for the benefit of consumers, not the industry. And its current rules on alcohol levels on wine labels were written in a different era, when wineries did not have today's technology to quickly and accurately determine how much alcohol is in a bottle of wine. Printing technology also has advanced. In Argentina, wineries stamp the alcohol level on the label late in the production process. There's no reason U.S. wineries can't do this.

Let's see what happens next!

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Jon Bjork said...

Good for you to ask, Blake!

Thinking out loud here: Let's say TTB is open to changing the ranges, what would you want to new range to be?

As you probably know, you could run the same lot of wine for alcohol over a few days and get slightly different results. So there would still need to be a range. I'm not sure what the new range should be, but there would probably have to be some sort of consensus before TTB would publish a proposed rule change.

W. Blake Gray said...

I think 0.5% tolerance is sufficient for both consumers and the industry. American wineries that export to Europe already have to stay in this range so we know it can be done.

Aaron said...

Thanks for taking this on and facing the Beast in his Lair of Bureaucracy, AKA the government :)

Keith Pritchard said...

An ebulliometer has accuracy of barely +/-.5%. Any sweetness really throws it off more. Distillation/hydrometer is theoretically more accurate but not likely as it is subject to more errors. Gas Chromatography (flame inj.) is accurate within a.1% range, but not many small wineries can afford about $30,000 for this equipment. We are supposed to be required to have an ebulliometer (I suspect a lot of small wineries don't as I asked one or two and they never asked me to see mine over 20 years ago on my initial) and if sweetness is in it you are not going to get under .5% error. Which over 14% with likely sweetness you might get within 1% with dilution. Which is the range for over 14%abv. As for the effect of the wine with different alcohol levels, I think within 1.5% is not that much effect on a person drinking, I suppose if you expect it to be 1.5% over and its 1.5% under label you could tell the difference. About all that matters practically is I know I will have a lot less effect from alcohol from a 8-10% German wine than a 12.5-14% Chardonnay. I really think you are making a mountain out of a mole hill so to speak. If you order mixed drinks in a restaurant or bar you sure are not going to know how much alcohol you are drinking. Even if a restaurant listed it, just pouring/mixing errors from the recipe would be off a lot. Myself my labels always read the same and I generally count on a normal sugar conversion rate. I had one several years ago that was off and was 11.68%( external lab after bottling) (hot fermentation) and my label says 12.5%. Not sure of the labs error, but if that was another .5% error lower I would still be within the range. Small wineries cannot afford $100,000 dollar labs and many have standard labels with the same target ABV and order larger runs of labels for economy. The difference is a less than 10 cent label can quickly become a 50 cent label in small runs and orders. I have had some wines from EU where I was sure the alcohol was off more than 1.5%. So I doubt their requirements and accuracy are any better except in very large operations. I would doubt hardly any food labels get within a 10% error rate on calories of food. Let alone as in wine the affect of the alcohol (or calories in food) on different people. We are likely more accurate on alcohol content than any food is on nutritional content. Just google the calorie subject as I did last year, you will be surprised.

jo6pac said...

Trouble maker and having complete faith in my govt. they'll move it to 2.5% or greater.

Unknown said...


You are correct. The margin of error for most nutrients, calories, etc. approved by the FDA on food products is greater than that for wine. Here's an article about that:

Adam Lee
Siduri Wines

drocto said...

Because for wines up to 14.0% abv, the TTB allows the label abv to be as much as 1.5 percentage points above *or* below the actual value, the consumer's uncertainty range can be as much as 3.0 percentage points, which is outrageous.

For example, if I see a wine labeled at 12.5% abv, the true value could be as low as 11.0% or as high as 14.0%.