The European Commission’s Directorate-General for Agriculture and Rural Development (DG Agri) has rejected the term ‘natural wine,’ inferring its hypothetical deceptiveness. A Pyrrhic victory for the lobbyists of the big wine industries, as the market for natural wines continues its unstoppable growth, even in Italy, regardless of the use of this or similar labels.
Thus, it will not be a name, in labeling and advertising, that will testify to the efforts of the operators who grow agrotoxin-free vines and produce wine without chemical adjuvants and additives. Rather, they will be the
blockchain
, QR-codes and apps-i.e., collective brands associated with specific specifications-will communicate and express the values of wines produced according to nature. As consumAtors, increasingly, demand.
Wine, the lobby of omertà and pesticides
CEEV(Comité Européen des Entreprises Vins) is the European wine producers’ lobby. And it is one of the most powerful, as evidenced by the disgrace of the unjustified exemption of alcoholic beverages from the requirement to list ingredients and nutritional values on the label. So much so that it is still admitted today that large producing countries such as France and Germany continue to conceal the legalized adulteration of must with sugar (so-called sugaring). And it is CEEV itself that has been advocating omertà on the composition of alcoholic beverages, in addition to various shenanigans such as ‘wood in wine‘ on Protected Geographical Indication (PGI) bottles.
The wine lobby has always sided with COPA-COGECA-the European confederation of agricultural confederations, dominated by Coldiretti-which on 20.10.20 scuttled the draft ecological transition of the CAP (Common Agricultural Policy). And it is closely linked to the Big 4, the global pesticide monopolists who find the largest market in conventional vineyards. It is no coincidence that in Prosecco-shire, as it turns out, consumption of agrotoxics accounts for 625 percent of the European average. And this is how the fury against natural wine is explained.
Natural wine, Brussels at the service of lobbyists
Large industries-the ones that command every representative organization, with the power of membership dues-have decided to counter the extraordinary market phenomenon of natural wines, which is incompatible with the financial logics to which their businesses are geared. CEEV therefore submitted a ‘question’ to DG Agri, on 15.4.20, aimed at contesting the use of the term ‘natural‘ as well as terms such as ‘vin nature‘, ‘vin méthode nature‘ in labeling and presentation of some Bacchus nectars.
The European Commission followed up on the lobbyists’ requests, in its letter 7.9.20 responding to CEEV. (1) The Brussels institution thus claimed that the adjective ‘natural‘ might be able to create an expectation in the consumer of a product of higher quality and ‘healthier’ than ‘ordinary’ wine, suggesting substantial differences in its composition and nature.
Instrumental topics
DG Agri relied on a restrictive interpretation of the applicable European regulations to make its assessments. With arguments instrumental to the thesis proposed by CEEV:
– the category ‘natural wine‘ is not included among the categories of grapevine products in Annex VII, Part II of reg. EU 1308/2013 (so-called Single CMO). Although no independent winemakers, to our knowledge, have requested the amendment of the Common Market Organization regulation,
– ‘Wine is the product obtained exclusively from the total or partial alcoholic fermentation of fresh grapes, whether or not crushed, or of grape must.’ (2) It is therefore legitimate to use the name ‘wine’ of products known as natural wines,
– ‘authorized oenological practices are used only to enable good winemaking, good storage or good aging of products.’ (3) And he would be missed, it is worth adding. Although, as is evident, such a broad definition of the targets for use of permitted processing aids and food additives leaves room for the imagination of the most daring winemakers.
Are all wines the same?
Brussels bureaucrats therefore infer that ‘all practices authorized in the EU are such that they preserve the natural and essential characteristics of the wine and do not cause a substantial change in the composition of the product.’ As if the use of substances derived from allergenic ingredients (e.g., milk, eggs)-to date not mentioned on most labels-has no impact on the composition of the product (and the safety of its consumption by allergic consumers). Or if the amounts of sulfur dioxide and sulfites were indifferent, with no need to mention other substances such as synthetic tartaric acid.
The last straw is the claim that any product could be placed on the market as ‘natural wine,’ subject to compliance with the ‘wine’ designation, ‘regardless of the authorized oenological practices used in its production and the fact that oenological practices were used.’ This, we add, would be misleading information. Where there are organizations, such as VinNatur, that have defined very strict specifications and criteria for analysis.
Consumer information
DG Agri officials then ventured on to a topic outside their area of expertise, Food Information Regulation (FIR). For a sterile reference to the general criteria of transparency and non-misleading of consumer information concerning foodstuffs, defined in Article 36 of Reg. EU 1169/11.
The use of the term ‘natural‘ associated with a wine would in itself be apt, for the lobbyists’ lackeys, to mislead consumers and ‘interfere with their rights to objective information.’ But the sex of angels is discussed, as the clarity and transparency of consumer information must instead be evaluated on a case-by-case basis. And one can hardly doubt the fairness of those who show (and can demonstrate) objective rigor, for example, in excluding chemical weed control and other agrotoxics from vineyards and certain winemaking practices.
Legal Reflections
‘This opinion is provided on the basis of the facts set out in your [CEEV’s, ed.] letter of April 15, 2020, expresses the views of the Commission services and does not bind the European Commission.’ DG Agri does not even dare to share its theorems with other DGs such as Sante, Grow and Competition. And he reminds, as dutifully, that the only official interpretation of EU law is that offered by the Court of Justice of the European Union.
Winemakers who wish to designate their wines and related production methods as ‘natural’ need only to precisely circumstantiate the meaning of such wording. Offering clear communication to consumers, as is stipulated in Regulation (EU) 1169/11. On this very basis, the French authorities have already recognized the legitimacy of using the term vin naturel. These products are appreciated, among other things, because they are metabolized better than conventional wines. And this is the only news that cannot be displayed on the label, although attested in a recent scientific study.
Dario Dongo and Silvia Giordanengo
Cover image: Pur Jus. Cultivons l’avenir dans les vignes, de Justine Saint-Lô et Fleur Godart, Marabout, 2016, 221 p., €22. ISBN : 9782501116671
Notes
(1) European Commission, DG Agri. Letter 7.10.20 to CEEV, document AGRI.DDG3.G.2/EM/RR(2020) 2580198, at https://news.unioneitalianavini.it/wp-content/uploads/sites/6/2020/09/reply_to_ceev_on_the_labelling_indication_natural_wine_20200907.pdf
(2) Reg. EU 1308/2013, Annex VII(Definitions, designations and sales descriptions of products referred to in Article 78), Part II(Categories of wine products), point 1
(3) Reg. EU 1308/13, Article 80(Oenological practices and methods of analysis), para. 102
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
Civil lawyer, master in Food, Law and Finance.
