This looks like a straightforward label, but it raises some good issues. “Napa” is on the “brand (front)” label. Should it be? On the one hand, it looks to be bottled in the Napa Valley. On the other hand, the appellation is California more broadly, as per box 14 of the label approval. The label mentions Napa three times, attesting to its obvious importance as a signal of quality.
Each reference to Napa tends to be accompanied by a clarifying explanation. One says it’s bottled there, two say the brand’s ownership is there. None of them (explicitly or by omission) suggest the grapes were grown there. TTB has approved quite a few labels presenting the same issues, and they may show a shift in policy, compared to five or ten years ago. It is our understanding that some wineries were blocked from highlighting Napa, regardless of the location of the bottling winery, if the grapes were from elsewhere.
The same label raises one more good (but rather technical) issue. The brand name and alcohol content statement are on one piece of paper. The varietal and appellation are on another. The rules require all four items to be on the brand label. Sometimes, TTB requires all four items on the same piece of paper, sometimes in the same field of vision. Here TTB allowed them to be divided across two pieces of paper in the same field of vision.
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Vegetable Wine
Earlier this week we covered kiwi wine. Today, we go further from grape wine, toward vegetable wine. Rhubarb wine to be exact. Rhubarbinfo.com says it’s a vegetable and on this I will tentatively defer to them.
Assumption Abbey Rhubarb Wine is made by Pointe of View Winery in Burlington, North Dakota. The TTB database has many rhubarb wines, and they tend to be made in states not well known for grape wine, such as Kansas, Iowa, Illinois, and Indiana. None of these labels tend to show an appellation of origin or a vintage date. In a good article about non-grape wine, the San Francisco Chronicle explains:
[TTB] allows fruit wine makers to add sugar, acid and water as needed – natural flavors and colors are even allowed – but they don’t allow a fruit wine to bear a vintage or place-name the way a grape wine does.
“I think it’s a waste to not allow vintage dating,” says Koehler. “You have good and bad years for fruit, just like you do for grapes.”
Those laws aren’t likely to change, if only because of the effort required by the TTB to police them. What does vintage mean to Tedeschi Vineyards when pineapple is available year-round? What does place-name mean to Galarneau when he buys mangoes from around the world?
It is difficult to locate the rules that prevent rhubarb and other non-grape wines from showing the vintage and appellation. Perhaps an astute reader can point them out.
Milk from Dragons, Grapes and Devils
In many areas, TTB is fairly literal-minded. For example, if you are bound and determined to mention energy on your label, you are unlikely to get very far, without much regard to context, as in this example. Likewise, good luck if you want to use the term “organic” on anything not in line with the organic rules.
In other areas, though, TTB will view a term much less literally. Mother’s Milk Shiraz is one such example. As best I can tell, it contains no milk. There is a recognition that the term is not to be taken seriously, even though it is quite possible to make a wide variety of alcohol beverages with and from real milk. This vodka distilled from milk is but one example.
If you gave up Mother’s Milk before third grade, you may prefer Dragon’s Milk. Another alternative is Devil’s Milk. Even without ingredient labeling I am reasonably sure that the Devil contributed no milk whatsoever to DuClaw’s ale.
Rejection: Refreshing
Quite a few readers have said, “yeah, unusual approvals are great, but what about rejections?” Here we have the first post of many, from time to time, showing common or revealing label rejections.
First, some ground rules. We will not show the brand or company at issue. TTB tends to treat label rejections as confidential and approvals as public, and we’ll mirror this sensible policy. To this end, we may blur out some identifying information where necessary, such as above. In rare cases, we’ll change a little bit of text (in the example above we changed about three letters to avoid the distraction that might otherwise be caused by typos; we did not change the substance). If you have a good and interesting rejection, please let us know and we’ll make sure to treat it in line with the policy above.
On to the controversial term at hand. For many decades, TTB has been concerned about the term “refreshing,” so common on all manner of beverages. TTB’s concern seems to be that it’s awfully close to a therapeutic claim, suggesting an effect on your body. “Invigorating” or “stimulating” would go a bit further and probably raise the same issues. Rather than ban the term “refreshing” outright — which would seem a bit out of proportion to the harm it could cause — TTB frequently says it must be accompanied, in close proximity, by something like “serve chilled.” The above rejection is such an example. It says “The statement ‘refreshing’ must be deleted or the statement ‘on the rocks’ or ‘serve chilled’ must be added.” This would tend to make it clearer that any effect on your body is rather innocent and fleeting. It’s not going to cure your eczema or chronic exhaustion.
This Franzia label pretty much shows how TTB wants the term used. “Refreshing” is fairly prominent on this label, but “Serve Chilled” is not too far behind.
By contrast, here are a few that seem to go in the opposite direction. Erik’s Refreshing Riesling does not seem to have much chill talk. Nor does this MillerCoors Honey Moon label (“A Refreshing Summer Ale with Honey & Orange Peel”).
We feel it’s important to set some of these policies out, because a lot of them do not appear in the regulations or BAM. As a result, they are inherently subject to confusion and surprise.
97 Ounces of … Obscenity(?)
It’s been a long time since any single wine label got as much press as the one above. We don’t want to rehash the Cycles Gladiator story yet one more time; it is well told here for example. Instead, we are curious about the lines dividing art, free speech and obscenity. TTB is regularly called upon to judge these matters. Today, it’s your turn to judge. Please take a peek (if you dare) and report your opinion in the poll below. A quick view of all four labels is here (this is the fastest and easiest view, for the poll).
[polldaddy poll=”2111484″]
Another view, showing the full label approval for each product, is below.
- A. Cycles Gladiator Red Wine
- B. Toogood Foreplay Red Wine
- C. Mendielle Vertu Merlot
- D. Naughty Nancy’s Nut Brown Ale
Go ahead and vote in the poll or comment or both.
Answer Honestly: Would You Prefer Funny Molson Labels?
Molson must be pretty darned excited about the prospects for the above marketing campaign. They seem to have hundreds of label approvals for variations on this theme. A lot of the “Answer Honestly” labels are quite amusing. Molson has a long way to go before passing Twisted Tea in the shocking hugeness of the number of labels submitted and approved.
This massive exercise tends to beg the question, why don’t they just submit a few labels, with a long list of approved permutations alongside. Perhaps TTB wants every one submitted separately but it’s still not clear why that should be the case, as opposed to the relatively common allowance for personalization (Happy Birthday Joe, Trudy, Eleanor, etc.).
Here are a few more good ones, among the hundreds. If you see good ones out in the market, please add them to the list by way of comments.
Answer Honestly, Would You Prefer….
- To be half your height -OR- Twice your weight?
- To be famous and hated -OR- Normal and respected?
- To have the ability to play every musical instrument -OR- Speak every language?
- To be able to change the past -OR- See the future?
- To be stuck in a meeting -OR- Stuck in traffic?
- To be ten minutes late for everything -OR- An hour early for everything?
- To lose a winning lottery ticket -OR- Your hair?
- To watch all TV in black and white -OR- Listen to all music in AM?
- To have a time machine -OR- A money-making machine?
- To be a corrupt mayor -OR- An honest lawyer?
- To hypnotize with your eyes -OR- Your touch?
- To be stuck on a deserted island with a supermodel -OR- A boat builder?
- To be rich -OR- Good looking?
- To have your dream house in the Arctic -OR- Be homeless living on a beach?
- To date someone who talks too much -OR- One who rarely speaks?
- To have a constant toothache -OR- No teeth at all?
Sign me up for writing the next 500 questions (especially if it comes with free beer, a year on a tropical island, and a fat budget).
