*(Author’s Disclaimer: This article is not meant to imply that Nielson has done anything misleading or underhanded in the production or sale of its Santa Barbara County Pinot Noir. The wine conforms in all ways to the legal bottling requirements for what is listed on the label. My use of the Nielson label in no way constitutes a criticism or endorsement of the wine or winery, nor does this article in any way seek to positively or negatively influence a reader’s impression of Nielson, or Byron wines. The article is an educational piece meant to demonstrate how to interpret the legally-disclosed information on an American wine label.)
Anyone who has been to one of my classes has heard me talk about the legal meaning of terminology on a wine label… Our Federal Government has created certain requirements for wine labeling and additional legal definitions for terminology found on a wine label. The requirements and definitions are there, presumably to protect the consumer, or at least inform the consumer about the product they are buying.
There are seven pieces of information that are required to be displayed on a wine label in the United States:
- Brand Name
- Wine Class or Type
- Fruit Wine, Rice Wine, Mead
- Sparkling Grape Wine
- Still Grape Wine (Generic, Semi-generic, Varietal)
- Table wine (wines less than, or equal to 14% alcohol by volume)
- Dessert Wine (wines more than 14% alcohol by volume)
- Fortified Wine (wines more than 15% alcohol by volume)
- Name & Address of Bottler
- Alcohol Content (tolerance +/-1.5% for <14%; +/-1% for >14%)
- Sulfite Statement
- Government Health Warning
- Net Contents
Other important definitions, are as follows:
Place of Origin Requirements (for a place name to be listed on the label):
- United States 100% from the named area
- State Name (Except CA) 75% from the named state
- California 100% from California (if so labeled)
- AVA 85% from the named AVA
- Specific Vineyard 95% from the named vineyard
Varietal Requirements (for a varietal to be listed on the label):
- 75% of named varietal (90% in Oregon)
Vintage Date Requirements (for a vintage to be listed on the label):
- 95% of the wine must originate from the listed vintage
Bottling Requirements (for bottling terms to be listed on the label):
- Produced 75%, or more of grapes crushed
- Made 10%, or more of grapes crushed
- Cellared, Selected, Vinted 10%, or less of grapes crushed
The terms: “Estate Bottled” and “Grown, Produced, and Bottled By” have special defined meaning on an American wine label.
Use of these terms is limited by the following criteria:
- The wine must list an AVA
- The winery must be located within the listed AVA
- The winery must have grown 100% of the grapes used to make the wine on the
land owned or controlled by the winery within the AVA (control is defined as “a
lease of at least three year’s duration”) - The winery must have crushed the grapes, fermented the resulting must and
finished, aged and bottled the wine in a continuous press.
Other proprietary terms, such as “reserve” or “meritage” have no defined meaning.
Trademarked terms have no defined meaning.
So what does this all mean? It means that wineries can craft their labels to tell whatever story they want, so long as the seven aforementioned label items are included. It also means that you need to be astute to fully understand where marketing ends and truth begins.
I was recently out to dinner with friends and is often the case, I was asked to select a wine from the restaurant wine list. Always looking for something interesting that also appears to be a good value, I landed on a domestic Pinot Noir from Santa Barbara county.
Let’s examine and dissect the following wine label:
*Author’s Note: The use of the Nielson Pinot Noir label in no way reflects the author’s impression of quality, but is merely used to illustrate the legal requirements and definitions of American wine labels.
For the seven required items, we have:
- Brand Name: Nielson (by Byron)
- Wine Class or Type: Table Wine
- Name & Address of Bottler: Nielson Wines, Santa Rosa, CA
- Alcohol Content: 13.5%
- Sulfite Statement: Present
- Health Warning: Present
- Net Contents: 750ml
Some other important terms found on this label:
- Santa Barbara County (Legal): 85% of the grapes in this wine came from Santa Barbara County – There is no vineyard statement, therefore, we can only conclude that the wine has no specific vineyard of origin.
- Pinot Noir (Legal): 75% of the varietal in the wine is Pinot Noir. The wine could be 100%, but legally, all we truly know is that 75% of varietal is Pinot Noir
- Vinted and Bottled By (Legal): This statement means that no more than 10% of the grapes in the wine were actually crushed by the winery listed. In actuality, none of the grapes needed to be crushed by the winery in order to use the term “vinted.”
- Original Vineyard Planted in 1964 (Marketing Statement): Absolutely no meaning to this statement, other than somewhere in the “history” of the winery, a vineyard was planted in 1964. There is nothing that legally connects this “original” vineyard to the wine in the bottle.
- Primary Soils, Barrel Regime and Flavor Notes (Marketing Statement): Absolutely no meaning to these statements. While the winery may be implying that the grapes were grown in a vineyard whose primary soils were “marine-derived sediments,” there is nothing on the label to legally connect this statement to the wine in the bottle. Furthermore, the Barrel Regime is merely a statement to how long the winery held the wine and in what medium they used – in this case – 16 months in French Oak. The Flavor Notes are merely one taster’s impression of the wine and again, have no legal meaning, but may be helpful in connecting style with personal preference.
Another point that is very subtle… On the back label the name of the winery (Nielson) has a trademark symbol and then the statement “by Byron.” This tells me that the actual winery behind this bottle is Byron and they are licensed to use the Nielson name, as well as tell the story on the label. Nothing about the origins of Uriel J. Nielson in 1964 necessarily have anything to do with this wine. I’m not saying this is deceptive, but it is very shrewd marketing indeed.
So, not to be too one-sided, like any thorough wine consumer, I visited the link on the label. I found a very flashy web site that told a wonderful story about the origins of Nielson wines, specifically that the wine “pays homage to its namesake, Uriel J. Nielson, who in 1964 planted the first commercial vineyard in Santa Barbara County.” Scrolling down, I find a brief paragraph about this “Nielson Vineyard.” Their wine maker seems to be quite the adventurer, as evidenced by his feats of rock climbing.
I drill downed further into the web site to find specific information about this Pinot Noir. I found the following:
2016
This wine comes from three major Pinot Noir growing regions within Santa Barbara County, each of which is influenced by unique soil types and proximity to the Pacific Ocean. Santa Maria Valley is one of California’s coolest AVAs with well-drained soils and one of the longest growing seasons in the world, brings pretty aromatics and red fruit flavors to the wine. Slightly warmer in climate, the Los Alamos area contributes ripe dark fruit flavors. Just south of Santa Maria Valley and Los Alamos, the Sta. Rita Hills AVA, characterized by steep vineyard slopes and a distinct gravel minerality, adds power, depth and austere tannin expression.
Interesting…
So, my conclusions… Byron is actually the winery behind Nielson. This is not necessarily noteworthy – I like Byron wines and market segmentation is important in wine making. It is fairly common today for wineries to be owned by larger parent wineries or holding companies. It is a fact that wineries demand extraordinary amounts of operating capital and sometimes, small, family-owned operations struggle and seek outside investors to ease the burden somewhat. Nothing wrong with this, just important to keep in the back of one’s mind.
However, the grapes in this specific wine had nothing to do with the Nielson Vineyard so lovingly described on the web site and it is highly likely that the wine was not even made by the winemaker at Nielson. They likely purchased an already made wine, or wines, from “three major growing regions in Santa Barbara County.” He took said wine and aged it in French oak in a storage facility, probably in Santa Rosa CA, not Santa Maria. Why Santa Rosa? Because the address on the back label states Santa Rosa. The address on the web site says Santa Maria. Santa Maria is the sexier address from a wine making perspective and the office or tasting room of the winery is in Santa Maria. However, the legal address of the wine’s bottler is Santa Rosa, as evidenced on the back label. Again, not terribly important, except you should know where the marketing ends and the actual truth begins – which was the premise when I started this article.
In closing, does any of the above matter? I guess if you like the wine and are happy paying what you pay for the wine, then all of the above can be filed under “legal arcana” and left at that. However, if you closely examine wines and try to understand linkages between soil, climate, grape growing and ultimately wine making, then this wine is a bit of an enigma. Readily available information on the wine would imply all kinds of things about vineyards, soils, climates, grape growing and wine making and yet, none of that is necessarily relevant given the legal statements on the label. Could I have written the winery or even made an attempt to speak to the wine maker himself? Sure, but they were fairly clear on the web site, even providing a PDF of wine information for my use.
That said, Nielson does produce several Pinot Noir wines from grapes grown on the Nielson Vineyard. The wines produced from these grapes are “Grown, Produced and Bottled by,” so we know that these are the real deal. However, they are between 2 and 3 times the listed price of the Nielson Santa Barbara County wine, the subject of this analysis. Again, none of this is a problem if you like the wine and don’t have an issue with the price…
Remember, I started this article by saying that the Federal Government requires and defines the statements on a wine label to “protect the consumer.” I would say they did their job, as long as you know the definitions behind the terminology.
Here endeth the lesson…
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