A Case Of Ethics – EU Organic Wine And Sulphur Dioxide

New Organic Wine Legislation for the European Union

The need for new, pan-European organic wine legislation has been recognised for some time now. ORWINE, a three-year research program which consulted and co-operated with organic winemakers in most European wine-producing countries, has just recently presented the European Commission with its final recommendations. Currently, no certification exists in Europe which would valorise the unique vinification methods used in organic winemaking; only the organic provenance of the grapes is recognised on the label. This is seen as a serious problem by most producers in Europe, as it makes them more vulnerable to competition from countries such as United States, where wines can be labelled \’organic\’, not just \’from organically grown grapes\’. One of the key areas of interest for the regulators looking at the new pan-European organic winemaking legislation is the limiting of SO2 use in the organic wine production.

As far as the SO2 use is concerned, ORWINE concluded in its report that while “it is not possible to produce ‘good’ organic wine without any addition of sulphites in a significant range of areas, wine types and years” (ORWINE 2009 p. 62), most producers support a reduction of sulphur dioxide use in organic wines. It will be interesting to see if the SO2 levels indeed get slashed in the new legislation. On the whole, I don’t think that we’re in for a major change, and I suspect the new regulation will have a very small impact on how the majority of organic producers make their wines. In Europe producers already strive to minimise sulfite levels, and most use SO2 in quantities well below the legal thresholds.

Organic wine in the EU: the current state of affairs

Currently, there is a width of substances, processes and additives allowed under the European organic winemaking certifications – in fact, many winemakers in Italy told me that as far as the work in the cantina is concerned, for all practical purposes there is no difference between an organic winery and a conventional one (in fact it is easy for a conventional wine company to have an organic production line along a conventional one, in the same building and largely using the same equipment). While a clear distinction on the level of rules and prohibitions can be made between organic and conventional practices in the vineyards, the distinction between the two production methods becomes more blurred once we cross the threshold of the winery.

There is a great diversity of production methods in organic vinification, from the least to the most technology dependent. Organic winemaking is not necessarily neither traditional nor low-tech, as producers are not obliged to stick to a strict production protocol, and can make use of modern developments. A hand-picked, hand-musted, oak barrel-aged Montepulciano D\’Abruzzo can bear the same \’organic\’ stamp as a machine-harvested, cold-macerated, multi-filtered Prosecco – and yet the production regimes of those wines, and personal ideologies of their producers, could not be more different. Add to this self-certifying producers, or those who do not acknowledge certification all together, and the organic wine landscape becomes even more complex. In a nutshell, it is up to the individual organic winemaker how they work with their wine – and it is up to the consumer to find out about the production method.

The expense of eliminating SO2

In an article in Harpers in 2005 Jamie Goode suggests there are four different approaches when it comes to using additives in wine: ‘anything goes’ (within the bounds of health), ‘add nothing’, ‘add as little as possible’, and ‘the in-between’ (additives are just tools that can be used well or badly). His categories describe well the attitudes I have come across when interviewing Italian organic winemakers about sulphur dioxide use. Most producers would agree with the ‘in-between position’ – sulphur dioxide is not bad per se, it is a helpful oenological tool and, used in moderation, can only bring positive results. Many producers I have spoken with, however, strive to limit or even eliminate sulphites from their wines, regardless of the risks.

While, especially in the North, it is very difficult to make wine without any SO2 at all, for many organic winemakers sulphur dioxide is linked with the industrial, homogenising, additive-heavy winemaking they want to distance themselves from. For some, limiting SO2 use is another way of being more \’natural\’ and \’authentic\’, a logical extension of their already existing production ethics. For those producers who already seek to differentiate themselves from the main-stream, homogenising wine market by producing \’particular\’, \’natural\’ wines, avoiding SO2 fits with the existing production ethics of the company. However, this kind of production strategy is not for everyone – it is much more difficult for an industrial-scale organic producer to make low sulfite wines than it is for a small family winery, mainly due to the risk involved if spoilage should occur.

Why use SO2 at all?

Sulphur dioxide is a substance much talked about, but rarely seen. Used either in the form of gas, liquid or powder, it is the most common preservative used in winemaking, and in food production more generally (known to us from food labels as E220). Its popularity is due its unique characteristics: even in minimal doses, it prevents both microbial activity and oxidation, and it is toxic to only a small percentage of the human population. The characteristics of sulphur have been known since antiquity, however the use of SO2 at all stages of vinification and wine keeping has become popular only in the 20th century.

SO2 and consumers.

In their focus group study with European consumers of organic and quality wines, ORWINE researchers found that in general consumers have very little knowledge of either the production methods or the additives used in organic winemaking – even if they are coneisseurs of organic food or wine. There was a general consensus that SO2 is ‘bad for you’, and should be limited, if not eliminated, from organic wines. In an interview with the Organic Wine Journal in 2008, Adam Morganstern sheds some light on the unfortunate series of events which led to the consumer perception of sulphites as ‘baddies’, without any knowledge of their positive qualities. This has led to the emergence of sulphite-free wines, which have created a market niche for themselves. It has to be said though that this kind of production strategy is not for everyone – and not for all the wines. Making ‘no sulphies added’ wines on an industrial scale is a complex and expensive process, which bears on the final price of the bottle. In short, if all wines were to be made sulphite-free, we would have to get used to spending much more on them.

It’s not about sales, it’s about the ethics.

Low sulphite wines are more prone to bacterial spoilage and oxidation, and it is more difficult for those wines to ‘sell themselves’ on the face-less international wine market. As a result companies that sell low-sulphite wines develop particular, information-heavy sales networks which require a lot of personal involvement from the producers. The whole company, both in production and in sales, has to adapt to the absence of SO2 and its consequences. The irony of this move is the fact that very few consumers realise what SO2 is at all, and what the consequences of limiting it are. In monetary terms, the expense of making low-sulphite wines far outstretches the advantages.

However altruistic it sounds, the fact is that organic wine producers who do strive to minimize SO2 in their wines do so not because of market pressures, or consumer demand, or regulations – but because they believe it is the right thing to do. They are, after all, in an ethical business.


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