Comment 2: Wernstrom, Todd M.

Document ID: TTB-2010-0006-0003
Document Type: Public Submission
Agency: Alcohol And Tobacco Tax And Trade Bureau
Received Date: November 09 2010, at 02:34 PM Eastern Standard Time
Date Posted: November 18 2010, at 12:00 AM Eastern Standard Time
Comment Start Date:
Comment Due Date: March 4 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80b8584c
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This is comment on Proposed Rule

Notice No. 109: Use of Various Winemaking Terms on Wine Labels and in Advertisements

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As the importer and distributor of limited-production, mostly single-vineyard wines from France, California and Washington State, I believe there is value in terms like "single vineyard." I can say that in my career, first as a wine writer and frequent consumer and industry speaker, and now as one who seeks out these types of wines to sell in New York City, I can't think of even one instance where anyone I was speaking to, whether involved in the industry or a consumer, understood the term "single vineyard" to mean anything other than that those grapes were 100% from that specified vineyard. It's really just a question of the plain meaning of the two words when they are put together. To allow some lesser percentage to qualify for the use of the term on a label does nothing but give the consumer something other than what he/she assumed they were getting.