Today was my attempt to reason with the TTB and explain to them why you absolutely CAN make wine with just grapes and sulfur and that it would be okay for our ingredients statement to list only those. Little did I know I would end up having an entire discussion about why wild ML is not allowed on wine labels (surprise!).
In a process that has now stretched about four months, I've been struggling to get a label approved by the TTB that allows us to list our ingredients for the Foursight 2010 Semillon (see my previous posts about this issue). Our ingredients list on the back label reads: grapes and sulfur dioxide. That's what we used when making the wine. Other substances/ingredients added to the wine: zero.
Now you think that, as the agency in charge of approving wine labels, that they'd just accept that people make wine in various styles. Some do a lot of tweaking, and some do little to none. We just happen to be on the none side with this bottling, but apparently they've never seen an ingredients statement with so few ingredients.
My last attempt to submit this label included a one-page rundown of our winemaking procedures per a representative's recommendation. From today's conversation, I now know one page is too lengthy for a TTB representative to read through. Come on, one page?
Also, by saying that the wine was fermented with wild yeast and wild ml in my one-page dissertation, it sounded like we added wild yeast and wild ml. WTF? Whether you call it wild, native or feral, if you know anything about wine terminology you know that using any of those words means that those little critters were absolutely not added. But, as I also learned today that you can't say wild ML on wine labels, without exception.
In the same non-reasoning that prevents the word fortified from being used and prohibits wineries from saying they've added brandy to their wines (her example), wild ML is simply not recognized by the TTB. I feel like throwing in a Scooby Doo-style "HUH?" here. Is this another Saturday Night Live "Really!?!" skit? Really?
And, to top it off, if I changed the sentence claiming that the wine was fermented with wild yeast and wild ml strains to "No yeast strains or ML cultures were added to this wine," then than would be a disparaging remark. In other words, I'd be belittling other wineries by claiming that I didn't add yeast or ML to one bottling of our own and insinuating that they did. (I was literally speechless after that one.)
So, I conceded. I'm removing my claim of wild ML and shortening my explanation to one sentence. Although no one could guarantee that would get my label approved, they thought the likelihood was high. And, in case pure ridiculousness reigns again, I'll have a generic back-up label on file to use for this vintage. But, mark my words, I'm not giving up!
My new mission for the next 12 months: try and get the TTB to recognize the use of wild ML on labels just like they did at one point with wild yeast. I'm sure it will be just as heartening and confidence-instilling as the current process has been.