Fruit Snacks, Organic Wine, and the Dilemma of "Made With"

This Welch's Fruit Snacks box is a great example of why I find the US National Organic Program (NOP) wine standard problematic. Seem like a leap? Bear with me.

These fruit gummies say “Made With Real Fruit”. And they are! But also a lot of other stuff, like corn syrup, artificial flavors, and Red 40. The phrasing "made with" is pretty clear in this case. This product contains real fruit. It's (in this case) the first ingredient, though it doesn't need to be. But the clear implication is that there are other ingredients. And there are, 17 in all, in these fruit snacks. 

So, why, if you look on a shelf in the "organic" section of your local wine shop or supermarket, do most of the wines there say “Made With Organic Grapes” on the label? After all, based on American labeling laws, the implication is that there’s other stuff in there, maybe even things that aren’t grapes. But it's one of the only options for wines, as dictated by the NOP standard.

This disconnect comes down to a long-standing (and in my opinion overblown¹) fear of sulfites. Sulfur has been used for centuries in winemaking because adding it in small amounts slows the process of oxidation and inhibits the action of vinegar-causing bacteria. But as I wrote early this year, how this got added to and then maintained in the organic regulations is a quirk of history and marketing from an unusual coalition of anti-alcohol interests, natural wine purists, and sulfite-free wineries: all parties with a vested interest in making organic wine hard to achieve.

Most other countries set a limit for sulfites for organic wines around 100ppm. That seems reasonable to me. But not the NOP. If you add any sulfites at all you can’t call your wine organic. You can't use the NOP organic seal. Instead there is a specific line in the NOP standards that says "Any use of added sulfites makes the wine only eligible for the “made with” labeling category; may not use the USDA organic seal." There is a specific meaning to the "Made With" claim in the NOP organic regulations. It's for products that are at least 70% but less than 95% organic. Think pasta sauce "Made With Organic Tomatoes" but including non-organic onions, spices, etc. By contrast, the "Organic" standards require that 95% or more of the finished product be from organic sources. Those products can use the organic seal. A wine from an organic vineyard with 100ppm sulfites is 99.99% organic. But it's not eligible for the organic seal. 

This may seem an esoteric worry. But the fact that American organic wine is forced to be sulfite-free makes many of them short lived and unstable. That implies to consumers that organic farming makes unreliable wine and reduces incentives for wineries to farm organically. It's probably not a coincidence that the percentage of wine grapes in California has lagged that in France, Spain, and Italy. It also makes American organic wine  less competitive with international organic wines. That's at least three clear negative outcomes.

Supporters of the NOP standards (and wineries who have built a market with sulfite-free wines) say that wineries should embrace the “Made With Organic Grapes” phrasing. But one look at that fruit snacks box should make it clear why that option comes with its own baggage.

Footnote:

1. Why overblown? Many people attribute to sulfites the "red wine headache" that is more likely a sensitivity to histamines, found naturally in grapes. Sulfite allergies can be serious, but such sensitivities are very rare, and usually manifest in respiratory symptoms. It is (purportedly) for people with these sensitivities that wines that add it carry a “Contains Sulfites” warning. But given that there are many other products including including dried fruit, frozen potatoes, frozen shrimp and many condiments that contain much higher sulfite levels and don't have to carry a warning label, I don't find that particularly convincing.