TTP wants to put more, not less, into your wines

Elaine Brown alerted to me about a petition that had just gone up on the TTB site.

I went right to it. The document is dense. It is complicated. And it is stunning.

Now when industry is using less, big wine wants to use more. The TTB should understand that commercial wine and real wine need different governance. If people buy wine in the supermarket they can expect flavorings. If buying what they consider fine wine, then that category should offer the consumer some protections.

Most of the petitions have been requested by Gusmer Industries, a sales and wine consultancy that has been invaluable to me to find out what is the latest on wine manipulations. They are particularly interested in increasing the nutrients as well as the maximum dosage of additions.

There are also proposed changes to wine processing, and a special request by Constellation Brands.  

I've tried to provide a cheat sheet. Please head to the website for a complete distillation, and if you don't think the amount of gum arabic, biotin, niacin, PVP, chitosan should be increased or even allowed, please speak up. 

Acacia (gum arabic): TTB is proposing to authorize a maximum use rate of 8 pounds of acacia per 1,000 gallons (1.92 grams per Liter (g/L)) of wine in the list of authorized wine and juice treating materials in § 24.246. Acacia is currently listed in § 24.246 as an authorized treating material to clarify and stabilize wine, subject to a limitation that its use shall not exceed 2 pounds per 1,000 gallons (0.24 g/L) of wine

This category has a limit of one percent acacia gum (rather than 2 percent); the functional effects for this category match TTB's uses as clarifying and stabilizing wine. TTB is correcting this mistake in this rulemaking by proposing to increase the maximum use rate of acacia gum in wine to 8 pounds per 1,000 gallons of wine. TTB's earlier administrative approvals authorizing the use of acacia at levels greater than 8 pounds per 1,000 gallons of wine are revoked.

Potato protein isolates: as a fining agent. 

Sodium carboxymethyl cellulose: to stabilize wine from tartrate precipitation at a level not to exceed 0.8 percent of the wine.

Chitosan: TTB is proposing to add chitosan from Aspergillus niger, at a use rate not to exceed 10 grams per 100 liters of wine, to the list of approved wine and juice treating materials contained in § 24.246. TTB administratively approved several industry member requests to use chitosan from Aspergillus niger to remove spoilage organisms, such as Brettanomyces, from wine.  

*** Chitosan previously used has been derived from crab shells, this Aspergillus niger is responsible for what we know as black mold. 

 Inositol (myo-inositol): TTB is proposing to add inositol to the list of authorized wine and juice treating materials in § 24.246 to be used as a yeast nutrient at a use rate not to exceed 2 ppm.

Polyvinyl-pyrrolidone (PVP)/polyvinylimadazole (PVI) polymer: wine treating material to be used for clarifying and stabilizing alcohol beverages. According to FDA FCN No. 320, the blend “is intended to be added directly to alcoholic beverages during the maturation process . . . is to be completely removed by filtration . . . and is limited to single use applications.” The amount must not exceed 80 grams per 100 liters of wine.

L(+) tartaric acid: TTB administratively approved several industry member requests to use L(+) tartaric acid, prepared using an enzyme from immobilized Rhodococcus ruber cells, to correct natural acid deficiencies and to reduce pH when ameliorating material is used in the production of grape wine.

The list of SIX new nutrients Gusmer wants added

Bakers yeast mannoprotein: TTB administratively approved the use of bakers yeast mannoprotein to stabilize wine from the precipitation of potassium bitartrate crystals,

Beta-glucanase: TTB is proposing to add beta-glucanase, at a use rate of 30 parts per million (ppm) of wine, to the list of approved wine and juice treating materials contained in § 24.246.

Biotin: The Gusmer petition proposed a maximum use rate for biotin of 25 ppb.

Calcium pantothenate (vitamin B5):  TTB administratively approved an industry member's request to use calcium pantothenate as a yeast nutrient in the production of wine.

Folic acid: TTB is proposing to add folic acid to the list of authorized wine and juice treating materials in § 24.246 for use as a yeast nutrient at a use rate not to exceed 100 ppb.

Magnesium sulfate:  Nutrient

Pyridoxine hydrochloride (vitamin B6):  Nutrient

Machinery

CROSS FLOW FILTRATION

Both nanofiltration and ultrafiltration are capable of reducing alcohol content in wine, and this proposed liberalization will provide industry members with more tools to reduce the alcohol content of wine.

REVERSE OSMOSIS IN COMBINATION WITH OSMOTIC TRANSPORT

TTB administratively approved several requests to use reverse osmosis in combination with osmotic transport to reduce the ethyl alcohol content in wine.

ULTRAFILTRATION

In two separate requests, an industry member requested to use ultrafiltration to separate red grape juice into high and low color fractions for blending purposes, and to separate white grape juice that had darkened due to oxidation during storage into high and low color fractions for blending purposes.

USE OF WOOD TO TREAT NATURAL WINE

 TTB is authorizing the use of toasted wood in this proposal. Section 24.185(b) would state TTB's position on the use of wood essences and extracts in the production of wine.

TTB is also proposing to remove the last sentence from § 24.225 (“Wooden storage tanks used for the addition of spirits may be used for the baking of wine”) and include it in the new § 24.185, and to remove the reference to oak chips from § 24.246 and include it in new § 24.185, in an effort to maintain in one location all regulatory provisions pertaining to the treatment of wine with wood.

ACCIDENTAL WATER ADDITIONS 

Search

Accidental? This is really funny. It's illegal to add water to wine but everyone uses "Jesus Juice" to bring down the alcohol. How do you drop tons of water into the tank by accident? Or is this just another way to increase sales of Reverse Osmosis?

TTB has approved the use of reverse osmosis and distillation to remove water from wine under TTB's authority in § 24.249. In those reviews, TTB considered how the accidental water addition occurred, the ratio of water to wine, and whether or not the requesting industry member has submitted similar requests in the past. TTB applied the following conditions to those approvals. The industry member must:

  • Return the wine to its original condition;
  • Transfer the wine to and from the distilled spirits plant for treatment in bond;
  • Not remove more water than was accidentally added;
  • Not alter the vinous character of the wine; and
  • Keep the usual and customary records of the processing.

TTB believes that proprietors should have the authority to remove small amounts of accidentally added water from wine using reverse osmosis and distillation without first seeking TTB approval. 

 

 

Other Issues for Public Comment and Possible Regulatory Action

++Reverse Osmosis To Enhance the Phenol Flavor and Characteristics of Wine and To Reduce the Water Content of Standard Wine

 

TTB has not received other requests from industry members to use reverse osmosis to improve the phenol and flavor character of wine. However, TTB did receive a request to use reverse osmosis to improve the “sensory quality” of finished wines and to evaluate the potential sensory benefit of water content reduction compared to the resultant loss of volume.

 

If you believe that the use of reverse osmosis for these purposes is consistent with good commercial practice, your comments should explain your position in detail, as well as provide guidelines/standards concerning how much water (maximum percentage) may be removed. If you believe that the use of reverse osmosis for these purposes is not consistent with good commercial practice, your comments should explain your position in detail.

 

LET THEM KNOW HOW YOU FEEL

 

  • Federal e-Rulemaking Portal:You may send comments via the online comment form linked to this document in Docket No. TTB-2016-0010 on “gov,” the Federal e-rulemaking portal, at https://www.regulations.gov. Direct links to the comment form and docket are available under Notice No. 164 on the TTB Web site a https://www.ttb.gov/wine/wine-rulemaking.shtml