Thank you, Simon, for this article on QR Code Regulation! We have significantly updated our original article to include the latest information from the Q&A. Indeed, Regulation is complex, subject to interpretations, and circles back to previous definitions. Moreover, laws occur at the country level. And there is no doubt that wine lobbyists will try to make things go their way.
In your article, you mention some facts and data from Raisin that are not 100% accurate, so we'd like to take this opportunity to clarify (note that Raisin has not been interviewed for this article):
* The QR Code Generator is free for Raisin's community, which means that 3,200 winemakers already listed can benefit from our service for free. And since we already have their data, creating a QR Code will take only 5 minutes. You can try it if you want ;-)
* Regarding the "claimed queue," we are currently at 4,206 winemakers to investigate, even "more than 3,000" stated 😊 If not yet listed as Natural on Raisin, winemakers need to contact us, send us their info and wait a maximum of 3 months (please have a little more patience considering the size of our team and the number of requests received)
* The Raisin subscription allows validated winemakers to access extra features, like editing their info, adding their wines, adding photos, and receiving their Raisin Sticker; there is no need to pay to access the QR code generator.
* Our business model is similar to yours: when people support us, we can continue doing what we do.
We conduct thorough analyses so that winemakers can enter our map. All natural winemakers who use our QR Code Generator for free have a little Raisin logo in their QR code, making it even easier for natural wine drinkers to recognize natural wines.
If you need further information, don't hesitate to reach out: we are here to help!
Thank you so much for these clarifications Jean-Hugues. I will share your comment separately just to give it a bit more attention. It's great news for winemakers that they can quickly and easily utilise your QR code and eLabel service.
Thanks for another highly-informative piece, Simon!
I am convinced that EU-mandated analyses will reveal a great deal more addition of tartaric acid than most consumers would anticipate. In an era when even German Riesling growers are tempted in that direction, one can be sure that the practice is widespread and, as the planet warms, increasingly so. Acidification is, for example, widespread in Burgundy for both reds and whites. I could imagine a clever winegrower arguing that the tartaric addition employed to keep his or her wine’s pH from reaching what he or she perceives as a perilously high level won’t actually show up in the finished wine, as it is often the case when tartaric acid is added to musts that it eventually precipitates out as sodium or potassium bitartrate, whose crystals the winemaker would then filter-out. I’ve tasted German Rieslings whose musts were acidified only to end up with less tartaric acidity in the finished wine than the must had in its natural state.
Apropos Burgundy – now on the subject of chaptalization – I would just like to reiterate a point I made to Simon in our discussion of natural wine’s defining characteristics: To the extent that justly prestigious winegrowers still add sugar to their musts, it is not for the sake of higher alcohol or more body in the finished wine (as might well have been their practice thirty or more years ago in “unripe” vintages) but instead follows a time-honored practice of tiny incremental additions during the course of fermentation as a means of prolonging it.
Little Wine’s platform encourages a winemaker to “tell [his or her] terroir-driven story” and their E-Zine is full of really excellent winemaker profiles written by Little Wine’s three-person staff, two of whom are co-founders of the U.K.’s Austrian-oriented Newcomer Wines. There is thus a lot that would qualify as promotional, and if the EU-e-labels feature of Little Wine’s website is somehow sufficiently walled-off to pass legal scrutiny, then that indicates a favorably lenient interpretation of EU law.
Thank you David. Yes, I agree, I think it will be very interesting if we actually get some perspective and clarity on who acidifies and when. I know this is possibly the thing that most winemakers like to talk about least. There is zero transparency.
Noted on chaptalisation, yes, Jasper Morris also reiterated this point to me a couple of years back. Still, whatever the purpose it is still quite interventionist and thus relevant to know, if one cares about that kind of thing (which I and many of my readers obviously do).
Great article, and so disappointing to see how something that could be so helpful to uncover the truth about so much of winemaking completely fails to do so…
Well I guess that was never the purpose unfortunately, and as others have said in the comments, there is way too much pressure from major producing interests that will do everything they can to avoid transparency.
Yeah that’s what I assumed as well. That makes it just even more important for people like us to tell the truth to the public when the governing institutions can’t!
Great read Simon - I really appreciated the way you pointed out how easily things can be hidden. I went to a seminar hosted by the SGV legal team on how to disclose as little as possible and how there would be a chance this regulation would be voided by the time champagne has to be comply ( 26/27 at the earliest if it is the 24 harvest)
A big one is chaptalisation. Which could remain under the radar as sugar is used in the 2nd fermentation and in the liqueur de dosage. There was a whole 30 minutes on how no vineyard products have to be included ( herbicides and pesticides) and since the liquor de dosage - in theory - is a secret it would mean that all champagne is just made from grapes and sugar and a little sulfites. (though acidification may have to be added soon if global warm in continues)
There you go, the most unnatural wine in the world will come out as clean as a whistle ! Therefore I agree with everyone that it has not that much value in its current state - but with a bit of tinkering it could become interesting.
It certainly seems to be trying its best. However, I do note Emma Bentley's comment that actually wine labelling has been way more permissive than many other areas of the food industry until now.
Thanks for the reminder that I need to do this : ) One additional point of the law that is worth mentioning is that the nutritional information needs to be in the language where the QR code is being scanned. So if you are scanning a an Austrian wine QR code in Spain it needs to automatically be translated to Spanish, which makes these 3rd party services invaluable as I don't want to be responsible for translating into the 24 official EU languages.
Thanks Chris, yes that is worth highlighting indeed.
Christina @ Little Wine also pointed out that it's more than just the language. E-labels have to take account of local appellation laws too, so for example if Appellation X doesn't permit grape variety to be shown on the label, that information must be hidden on the page.
Thank you, Simon, for this article on QR Code Regulation! We have significantly updated our original article to include the latest information from the Q&A. Indeed, Regulation is complex, subject to interpretations, and circles back to previous definitions. Moreover, laws occur at the country level. And there is no doubt that wine lobbyists will try to make things go their way.
In your article, you mention some facts and data from Raisin that are not 100% accurate, so we'd like to take this opportunity to clarify (note that Raisin has not been interviewed for this article):
* The QR Code Generator is free for Raisin's community, which means that 3,200 winemakers already listed can benefit from our service for free. And since we already have their data, creating a QR Code will take only 5 minutes. You can try it if you want ;-)
* Regarding the "claimed queue," we are currently at 4,206 winemakers to investigate, even "more than 3,000" stated 😊 If not yet listed as Natural on Raisin, winemakers need to contact us, send us their info and wait a maximum of 3 months (please have a little more patience considering the size of our team and the number of requests received)
* The Raisin subscription allows validated winemakers to access extra features, like editing their info, adding their wines, adding photos, and receiving their Raisin Sticker; there is no need to pay to access the QR code generator.
* Our business model is similar to yours: when people support us, we can continue doing what we do.
We conduct thorough analyses so that winemakers can enter our map. All natural winemakers who use our QR Code Generator for free have a little Raisin logo in their QR code, making it even easier for natural wine drinkers to recognize natural wines.
If you need further information, don't hesitate to reach out: we are here to help!
Best Regards,
The Raisin Team.
Thank you so much for these clarifications Jean-Hugues. I will share your comment separately just to give it a bit more attention. It's great news for winemakers that they can quickly and easily utilise your QR code and eLabel service.
Thanks for another highly-informative piece, Simon!
I am convinced that EU-mandated analyses will reveal a great deal more addition of tartaric acid than most consumers would anticipate. In an era when even German Riesling growers are tempted in that direction, one can be sure that the practice is widespread and, as the planet warms, increasingly so. Acidification is, for example, widespread in Burgundy for both reds and whites. I could imagine a clever winegrower arguing that the tartaric addition employed to keep his or her wine’s pH from reaching what he or she perceives as a perilously high level won’t actually show up in the finished wine, as it is often the case when tartaric acid is added to musts that it eventually precipitates out as sodium or potassium bitartrate, whose crystals the winemaker would then filter-out. I’ve tasted German Rieslings whose musts were acidified only to end up with less tartaric acidity in the finished wine than the must had in its natural state.
Apropos Burgundy – now on the subject of chaptalization – I would just like to reiterate a point I made to Simon in our discussion of natural wine’s defining characteristics: To the extent that justly prestigious winegrowers still add sugar to their musts, it is not for the sake of higher alcohol or more body in the finished wine (as might well have been their practice thirty or more years ago in “unripe” vintages) but instead follows a time-honored practice of tiny incremental additions during the course of fermentation as a means of prolonging it.
Little Wine’s platform encourages a winemaker to “tell [his or her] terroir-driven story” and their E-Zine is full of really excellent winemaker profiles written by Little Wine’s three-person staff, two of whom are co-founders of the U.K.’s Austrian-oriented Newcomer Wines. There is thus a lot that would qualify as promotional, and if the EU-e-labels feature of Little Wine’s website is somehow sufficiently walled-off to pass legal scrutiny, then that indicates a favorably lenient interpretation of EU law.
Thank you David. Yes, I agree, I think it will be very interesting if we actually get some perspective and clarity on who acidifies and when. I know this is possibly the thing that most winemakers like to talk about least. There is zero transparency.
Noted on chaptalisation, yes, Jasper Morris also reiterated this point to me a couple of years back. Still, whatever the purpose it is still quite interventionist and thus relevant to know, if one cares about that kind of thing (which I and many of my readers obviously do).
Little Wine's e-label app seems to be fairly well separated from the rest of their site, although there is a link from the e-label back to their homepage. Here is a sample Little WIne e-label: https://app.littlewine.io/e-label?wine=examplewinemaker-examplewine-2023
Great article, and so disappointing to see how something that could be so helpful to uncover the truth about so much of winemaking completely fails to do so…
Well I guess that was never the purpose unfortunately, and as others have said in the comments, there is way too much pressure from major producing interests that will do everything they can to avoid transparency.
Yeah that’s what I assumed as well. That makes it just even more important for people like us to tell the truth to the public when the governing institutions can’t!
Great read Simon - I really appreciated the way you pointed out how easily things can be hidden. I went to a seminar hosted by the SGV legal team on how to disclose as little as possible and how there would be a chance this regulation would be voided by the time champagne has to be comply ( 26/27 at the earliest if it is the 24 harvest)
A big one is chaptalisation. Which could remain under the radar as sugar is used in the 2nd fermentation and in the liqueur de dosage. There was a whole 30 minutes on how no vineyard products have to be included ( herbicides and pesticides) and since the liquor de dosage - in theory - is a secret it would mean that all champagne is just made from grapes and sugar and a little sulfites. (though acidification may have to be added soon if global warm in continues)
There you go, the most unnatural wine in the world will come out as clean as a whistle ! Therefore I agree with everyone that it has not that much value in its current state - but with a bit of tinkering it could become interesting.
Wow, that's pretty nuts to have a whole seminar devoted to how you can fool the public....
Welcome to Champagne !
Sometimes I feel that the EU is going to regulate itself out of existence.
It certainly seems to be trying its best. However, I do note Emma Bentley's comment that actually wine labelling has been way more permissive than many other areas of the food industry until now.
Thanks for the reminder that I need to do this : ) One additional point of the law that is worth mentioning is that the nutritional information needs to be in the language where the QR code is being scanned. So if you are scanning a an Austrian wine QR code in Spain it needs to automatically be translated to Spanish, which makes these 3rd party services invaluable as I don't want to be responsible for translating into the 24 official EU languages.
Thanks Chris, yes that is worth highlighting indeed.
Christina @ Little Wine also pointed out that it's more than just the language. E-labels have to take account of local appellation laws too, so for example if Appellation X doesn't permit grape variety to be shown on the label, that information must be hidden on the page.
Excellent overview, Simon. Essential reading.
Thank you Valerie, I'm glad it's useful.
Not surprised, but sad and disappointing indeed...
Yes, it is a bit. But I'm sure there was plenty powerful lobbying by major winery interests to make sure they don't have to list everything.