Hello,
The USDA's second proposed rule does state in the "supplementary information"
"The Secretary has not accepted the NOSB recommendations to allow sulfur
dioxide in the production of wine labeled as "made with organic grapes."
OFPA mandates that if the Secretary decides to allow labeling under Section
2106(B)(c) "EXEMPTIONS FOR PROCESSED FOOD. Subsection (a) shall not apply to
agricultural products that
(1) contain at least 50 percent organically produced ingredients by weight,
excluding water and salt, to the extent that the Secretary, in consultation
with the National Organic Standards Board and the Secretary of Health and
Human Services, has determined to permit the word "organic" to be used on the
principal display panel of such products only for the purpose of describing
the organically produced ingredients; or
(2) contain less than 50 percent organically produced ingredients by weight,
excluding water and salt, to the extent that the Secretary, in consultation
with the National Organic Standards Board and the Secretary of Health and
Human Services, has determined to permit the word "organic" to appear on the
ingredient listing panel to describe those ingredients that are organically
produced in accordance with this title. "
the processed food products are exempt from all requirements of "subsection
(a) of Section 2106.
That means all wines using the labeling "made with organically produced"
grapes can use sulfur dioxide or substances that evolve to sulfites with out
hinderance, and still label their products "made with organically produced"
grapes. Sulfites are plainly prohibited in products labeled and sold as
"organically produced" under OFPA section 2111(a)(3).
So, what is the concern about?
Nothing in the proposed rule would "eliminate the use of the term "made with
organically grown grapes" from the labels of wines produced from certified
organic vineyards."
The Secretary forgot to proofread the proposed rule for consistency to OFPA.
"The Secretary has not accepted the NOSB recommendations to allow sulfur
dioxide in the production of wine labeled as "made with organic grapes" is
without question in violation of OFPA. The labeling language "made with
organically produced grapes" is distinctively and legally different from the
labeling language "organic wine" or "organically produced wine." The NOSB
final recommendation regarding "made with organic grapes" is correct legally
and consistent with present wine handling operation language usage to my
knowledge.
"The USDA ruling would allow only those producers not adding any sulfur
dioxide to their wines to claim the term "organic." In this case the
primary lableing panel language would be "organic wine" for which legally
under OFPA no sulfites can be added. This is consistent with the
requirements of OFPA.
If the French want to use sulfites in wines made with organic grapes they too
will have label their imported products "made with organically produced
grapes."
Best, Eric Kindberg
Ripplebrook Organic Growers.
Fairfield, Iowa
> New USDA Proposal Threatens Future of Organic Wine Industry; Organic
> Grape
> Growers and Producers Mount Massive Response to USDA Ruling
>
> HOPLAND, Calif.--(BUSINESS WIRE)--May 26, 2000--A new group of organic
> wine
> industry leaders, Organic Wines International (OWI), has been formed to
> challenge a proposed ruling by the USDA that would eliminate the use of
> the
> term "organically grown grapes" from the labels of wines produced from
> certified organic vineyards. This ruling comes at a time when
> organically
> grown foods and wines are gaining widely in consumer acceptance.
>
> Headed by prominent growers, winemakers, and importers of organically
> grown
> wines, OWI is attempting to provide new insight to the USDA, whose
> recent
> unexpected ruling on organic labeling has caused a major stir in the
> organic
> wine community. The USDA opinion fails to heed input initiated in 1995
> and
> reiterated again in 1998 from the National Organic Standards Board
> (NOSB),
> the group appointed by USDA to advise on such issues.
>
> The USDA ruling would allow only those producers not adding any sulfur
> dioxide to their wines to claim the term "organic." The terminology
> "made
> from organically grown grapes" would be eliminated by the recent ruling.
> OWI
> is seeking to unify support and generate a massive consumer
>
> letter-writing
> campaign to USDA opposing the ruling during the inquiry period, which
> ends
> on June 12, 2000.
>
> Already, over 40 U.S. Congressional members, including Mike Thompson (D)
> and
> George Radanovich (R) from California, have responded to the USDA ruling
> with a letter indicating their opposition.
>
> Winemaker Robert Blue with Bonterra Vineyards offers, "The recent ruling
> by
> USDA misses the whole point of growing grapes organically, and, if
> adopted,
> it would set the industry back light years. All of the hard work we've
> put
> into achieving certification of our vineyards would be nullified if
> we're
> not allowed to truthfully state, as we have in the past, that the wines
> are
> made from 'organically grown grapes'."
>
> Pointing out the important role of sulfur dioxide in producing quality
> wines, Veronique Raskin, whose family owns organic vineyards in France,
> comments, "Sulfur dioxide has been used by winemakers in the production
> of
> quality wines for centuries, dating back to Greco-Roman times. As an
> anti-bacterial, anti-oxidant agent, there is no current suitable
> alternative
> to ensure consistently shelf-stable wines."
>
> The wine industry has utilized the "Contains Sulfites" warning,
> currently
> required by the BATF on all wine labels since 1987. "This statement
> clearly
> informs and protects the small percentage of consumers who are
> hyper-sensitive to sulfites, which are a by-product of sulfur dioxide,"
> says
> Brian Fitzpatrick, owner of the small Fitzpatrick Winery, established in
> 1980, and a pioneer in the organic wine movement.
> Ron Bartolucci, a veteran organic grape-grower, explains, "If the use of
> sulfur dioxide is forbidden in organic wine production, the demand for
> certified organically grown grapes will be drastically diminished, if
> not
> totally eliminated. This will nullify the incentive and long-term
> commitment
> for current and future growers to pursue sustainable growing practices
> that
> protect the environment and contribute to high quality, shelf-stable
> wines."
>
> OWI recommends that all interested wine industry members and wine
> consumers
> address this issue by offering input to the USDA prior to June 12, 2000.
> For
> further information and a sample letter, which can be sent to USDA,
> please
> visit the web site www.organicwines.org/OWI/comment.html.
>
> Organic Wines International includes Veronique Raskin, President, Dr.
> Michel
> Ginoulhac, VP, and Nina Zeiger, Marketing Director of Organic Wine Co.,
> who
> import French organically grown wines; Robert Blue, winemaker of
> Bonterra
> Vineyards, one of California's most successful and critically-lauded
> organically grown wine brands; Paul Chartrand of Chartrand Imports, who
> pioneered the sales of organic wines in the U.S. in 1985; and Ron
> Bartolucci, independent organic grower and viticulture consultant to
> Fetzer
> Vineyards, one of the most prominent organic wine growers in the world;
> and
> Brian Fitzpatrick, owner of the pioneering Fitzpatrick Winery.
>
> CONTACT:
> Brown-Forman Wines
> Sid Goldstein, 415/444-7441
> ----------------------------
>
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