The use of sulfites in organic winemaking brings out very strong opinions on both sides of the issue, and the Organic Wine Journal now finds itself in the middle of this debate. We'd like to present the following letters for our readers to hear two different opinions on this subject.
Organic Vintners recently starting offering "Organic Wine Journal" selections to our readers; a chance to sample different collections at a discounted price. When we wrote about this, Paolo Bonetti, President of Organic Vinters, asked that we refer to these wines as "certified organic," which we did.
This drew the following response from Phaedra LaRocca Morrill, of LaRocca Vineyards.
I would like to bring to your attention the difference between Made with Organic Grapes and "Certified Organic Wines" as mentioned in the section about Organic Vintners. According to the USDA National Organic Program Standards, to say that it is an ORGANIC WINE you cannot have added sulfites. And I am confident in the fact that 99% of all Organic Vintners wines are imports and domestic wines that have added sulfites. Hence, it is misinforming the public that their wines are indeed organic. It is best to use the terms "Made with Organic Grapes" or Organically farmed.
LaRocca Vineyards is truly an organic winery, from vine-to-bottle. We not only have the vineyard certified organic, but the winery is organic and we do not use sulfites. Hence, we are able and do use the USDA organic seal on the front label. There is only a handful of organic wineries and we are one of them.
It confuses people when they read articles and want a true organic wine, but then find out there are chemical additives like sulfites. Don't want to be annoying, I just feel that for those that truly support, and are all organic, it is not accurate terminology.
Phaedra LaRocca Morrill
We forwarded that letter to Paolo Bonetti, and received this response:
This is a can of worms and I will do my best to give you my clear information and please remember this is my interpretation of the law, and my opinion on how the word “organic” is used. I agree and I disagree with the statements made by Phaedra. Here's what I think, and I am always open to discussion.
Wine labels are controlled by the Tax and Trade Bureau and all wine labels for US sales must have an approved COLA (Certificate of Label Approval.) Any label making an organic claim must also show legitimate documentation of its organic legitimacy through a USDA accredited certifier. The TTB and USDA have an agreement that wine labels making organic claims can be processed by the TTB without going to the USDA as well. The size of the word organic is controlled and its size must be 50% of the height of the brand name. As Phaedra points out, if the wine has no added sulfites (AKA, sulfur dioxide, SO2), the organic claim can be "organic wine" and the green USDA Organic seal may be used. If the wine contains added sulfites and the final count of sulfites is less than 100 parts per million (ppm), organic claim may be labeled as "made with organic grapes" and the USDA seal may NOT be used.
KEY WORD ABOVE: ADDED--important to know is that some yeasts used in winemaking produce "naturally occurring" sulfites in the fermentation process and therefore some "organic wine" may have naturally occurring sulfites to the tune of 20ppm, so now that wine is 99.998% organic grapes and .002% sulfites.
Lets do some quick math by dividing 100 parts per million by 10 several times over: 100 ppm is equal to 10 parts per 100,000 which = 1 part per 10,000 = .1 parts per 1,000 = .01 parts per 100. Therefore, "wine made with organic grapes" cannot have more than .01% sulfites which means it is AT LEAST 99.99% organic grapes.
Wait! There's more: " . . . it would be hard to maintain the notion that wine is an ethereal elixir if, before uncorking, consumers read that their Pinot Noir or Syrah contained Mega Purple (a brand of concentrated wine color), oak chips or such additives as oak gall nuts, grape juice concentrate, tartaric acid, citric acid, dissolved oxygen, copper and water. The mention of bentonite, ammonium phosphate and the wide variety of active enzymes used to make some wines would end the romance. "--What's Really in That Wine, Los Angeles Times, March 28, 2007, by Corie Brown, attached. So how much of that 99.99% or 99.998% is organic grapes?
Legally speaking, what one can say on a label, Phaedra is correct. And Phaedra is also correct that all our wines are sulfite-added wines. Most of our wine labels say "made with organic grapes" and some say "made with biodynamic grapes" which is also regulated with proper documentation.
What retailers choose to do is not under the jurisdiction of the USDA, and unfortunately many organic wine sections have intruders on us legitimate people: Lolonis Lady Bug Red (USA) and Conosur Pinot Noir (Chile) are this year's biggest intruders. They make absurd but TTB-allowable claims like "no lady bugs were harmed" and "ecologically farmed grapes" which are not regulated by the TTB or the USDA. These products are the real culprits in the denigration of the word organic and whether they do it intentionally or not does not matter to me. Those wines are taking up my certified organic farmer’s and La Rocca's shelf space! I am not accusing these winemakers of making any false representations, but somewhere along the supply chain between farmer and retailer (distributor, importer, retailer, broker, sales rep, and then some) these “sustainable” wines become organic.
When speaking or writing I call my wines "organic", organic wines", and "wines made with organic grapes" interchangeably but more commonly use the word certified in order to distinguish myself from the growing number of illegitimate green wines like the abovementioned. So I may say "certified organic", “certified organic wines", and "wines made with 100% certified organic grapes," and its really up to you as a retailer to call them as you wish. My imports and La Rocca wines are virtually 100% organic. We both have the documentation that proves that the vines, the vinification process, and the whole facility are certified organic, from vine to bottle. If this were not the case we could not have the great privilege to use the word organic on our labels.
Now I will quote the USDA's National Organic Program rules from http://www.access.gpo.gov/nara/cfr/waisidx_07/7cfr205_07.html.
Through my exhaustive reading of the entire National Organic Program regulations, I summarize the facts:
➢ Wine is singled out in a “product composition” statement requiring 100% organic ingredients as follows in CFR, Title 7, Subpart D, § 205.301 (f), (5) and (7):
➢ (f) All products labeled as “100 percent organic” or “organic” and all ingredients identified as “organic” in the ingredient statement of any product:
o (5) must not contain sulfites, nitrates, or nitrites added during the production or handling process, except, that, wine containing added sulfites may be labeled “made with organic grapes”;
o (7) must not include organic and nonorganic forms of the same ingredient.
Phaedra claims that there chemical additives like sulfites; true. Scientifically speaking, alcohol, Potassium L-Bitartrate (in the form of C4H5O6K), acids such as H2SO4, C2H4O2, C4H6O6, sodium chloride (AKA salt or NaCl), and Potassium Sulfate K2SO4 are just a few of the many chemicals found in a basic chemical analysis of most wines. These are naturally occurring as is SO2.
My one point of disagreement and I defend all certified organic wine producers world-wide: I strongly disagree with Phaedra's claim that "There is only a handful of organic wineries and we are one of them." All my growers and hundreds of others practice certified organic farming and crush in a certified organic facility, from vine to bottle and there is simply no way to dispute this reality.
Conclusion. There is an ingredient difference of 80ppm which sets the two categories apart according to government regs and this does not make any farmer more or less organic as long as they are legitimately certified, like La Rocca and all our farmers. Retailers such as Whole Foods have wine sections they call "eco-farmed," "eco-friendly," "sustainable," and few use the word organic. The Organic Wine Journal does not make wine labels and I think it is up to you to make a decision about what words you use.
In any case I support the Organic Wine Journal's efforts which have so far been true and accurate. And I support all certified organic farmers who also use permissible USDA NOP 'chemicals' such as SO2 and bentonite clay (this is what makes our wines vegan.)
PS-Sulfites have been used in winemaking since 1400's and NSA wines are predominantly a US phenomenon.
The debate doesn't end here. Read Part II; where Phil LaRocca weighs in on the subject.