Labelling + Content
- Written by Mark Hicken Mark Hicken
- Category: Labelling and Content Laws Labelling and Content Laws
- Published: 02 April 2008 02 April 2008
The Wines of Marked Quality Regulation is the guts of BC's new wine labelling and content regulation. It creates 2 categories of wine: 1) the familiar "BC VQA" wine category which is actually a slightly watered down version of the old one, and 2) a new lesser category, the "BC Wine of Distinction". BC VQA wines must meet all the requirements of the BC Wine of Distinction plus some additional ones (the most contentious of which is a taste test).
Caution: Readers should note that these BC regulations only apply to wines that are made from 100% BC grapes. Certain wines are marketed in BC as being from British Columbia (often in government liquor stores) when a close review of the label (usually the fine print on the back) will reveal that they are actually a "blend of imported and domestic wine". Such wines are usually referred to as "Cellared in Canada" (CIC) wines. CIC wines have no BC regulations governing them at all (although federal labelling laws do apply) and normally consist of almost entirely (e.g. 99%) imported bulk wine. These wines are NOT BC wines.
Restricted Usage of Certain Terms
The following terms are restricted (s.4 and 28) and you can't use them on your wine labels unless you qualify within the regulation: BC VQA, British Columbia Vintners Quality Alliance, British Columbia VQA, BC wine of distinction, Icewine, Sparkling Icewine, Late Harvest, Meritage, Select Late Harvest, Special Select Late Harvest, Vin du Curé, plus the following geographical terms - British Columbia, Fraser Valley, Okanagan Valley, Similkameen Valley, Vancouver Island, BC Gulf Islands.
BC Wine of Distinction Content Requirements (s.18)
Wine must be produced entirely from fresh grapes, grape juice and grape must derived from grapes grown in British Columbia. Must be entirely fermented, processed, blended and finished in British Columbia. No vitis labrusca grape varieties are permitted. Must be certified according to the regulation. Must comply with federal Food and Drugs Act.
BC VQA Content Requirements (s.18.1)
Must be made from the varieties of grapes listed in Tables 1 or 2 of Schedule 5 (lists the expected quality varieties). Must pass the taste test under the regulation. Must conform to any other requirements that are added later.
Winemaking Rules (s.21-25)
Contains rules respecting the use of sweet reserve (grape juice sweetener - s.21), chaptalization (adding sugar - s.22), prohibits adding water (s.23), acidification (s.24), deacidification (s.25).
Varietal Content Requirements (s.26)
If the wine is labelled as being a single varietal (e.g. "chardonnay") then at least 85% of the total wine by volume must be derived from that varietal (so up to 15% does not have to be that variety).
If the wine is labelled as being a dual varietal (e.g. "cabernet merlot") then at least 90% of the total wine by volume must be derived from those varietals (and at least 15% of that percentage must be from the second varietal).
If the wine is labelled as being a triple varietal (e.g. "cabernet merlot syrah") then at least 95% of the total wine by volume must be derived from those varietals (and at least 15% of that percentage must be from the second varietal and at least 10% from the third varietal).
Geographical Content Requirements (s.27-29)
To use the term "British Columbia", 100% of the grapes must have been grown in BC.
To use any of the other prescribed terms (Fraser Valley, Okanagan Valley, Similkameen Valley, Vancouver Island, BC Gulf Islands), 100% of the grapes must be grapes grown in BC with at least 95% being grown in the more specific prescribed area. For example, if you use Okanagan Valley then at least 95% of the grapes must have been grown in the Okanagan Valley with the balance from elsewhere in BC.
Use of Vineyard Names (s.32)
Specific vineyard names can only be used if the vineyard has been registered with the BC Wine Authority and 100% of the grapes come from that vineyard. Vineyards must be within one of the prescribed geographical areas.
Use of Estate Bottled
Covered by s.33. 100% of the grapes must be from the same year and from land controlled by the certificate holder. Must be within a prescribed area other than "British Columbia". Certificate holder crushed, processed and bottled the grapes. Wine did not leave winery after being bottled. Winery must be in same geographic area where grapes were grown.
Use of Vintage Date
For a BC wine of distinction, at least 85% of the grapes must be from the year specified as the vintage year.
Section 37 sets out some general requirements. For example, you can't purposely use the tolerance levels specified by the regulation to blend in grapes which would otherwise not be permitted due to their variety or origin. A minimimum brix level for the grapes is set out in Schedule 1. Permissible alcohol levels and residual sugar levels are set out in Schedule 2. Labelling must comply with sections 52 to 55.
There are also some requirements for particular types of wines: blanc de noirs (s.38), nouveau wine (s.39 - this is not defined, please enlighten me!), sparkling wine (s.40-42, 44), ice wine (s.43, 48, 49), fortified wine (s.45), liqueur wine (s.46), solera wine (s.46.1), late harvest (s.47), vin de cure (s.50) and meritage, both white and red (s.51).
Section 53 governs BC wines of distinction. Section 54 governs VQA wines.
For wines of distinction, the label may contain a prescribed geographical area (e.g. Okanagan Valley) and/or a grape varietal (e.g. Chardonnay). If the label contains a prescribed geographical area and if the conditions are met, it may also contain the name of the vineyard and/or the term "estate bottled". You can't use names or descriptions which are misleading as to the wine's quality, content or origin including the use of foreign countries or geographical areas (e.g. you can't call your wine "Okanagan Chablis"). The category of the wine (s.35) must be displayed on the label (unless it is Table Wine). If the varietal and geographical area are used, the varietal name must be immediately before or after the geographical area. If you list more than one varietal, they must be listed in descending order of quantity used in the wine with identical font sizes and colors. Vintage year may be declared. The only sweetness descriptions permitted are those set out in Schedules 1 and 2.
For VQA wines, the label must display: 1) a VQA indicator, 2) the prescribed geographical area, 3) either the varietals used or a proprietary name, and 4) the vintage year (except for sparkling wine, fortified wine, liqueur wine and private labelled wine). You can't use names or descriptions which are misleading as to the wine's quality, content or origin including the use of foreign countries or geographical areas (e.g. you can't call your wine "Okanagan Chablis"). If the varietal name is used, the varietal name must be immediately before or after the geographical area. If you list more than one varietal, they must be listed in descending order of quantity used in the wine with identical font sizes and colors. The only sweetness descriptions permitted are those set out in Schedules 1 and 2. For sparkling wine, it must indicate whether it is produced using the traditional method or cuvee close (which are the only two methods permitted for VQA sparkling).
Late harvest wine may use the terms "botryitis affected" or "botrytized". Ice wines must list the varietal(s) used. Sparkling wines may contain the terms "Blanc de Blancs", "Blanc de Noirs", "Fermented in this bottle" and "Rosé". Liqueur wine may use "natural".
The permitted size of bottles is listed in section 56(4). Permitted closures are listed in section 56(2) and (3).
Schedule 1 lists minimum brix levels for grapes at harvest for wines of distinction.
Schedule 2, table 1 sets our permissible sweetness descriptions (e.g. dry, medium-dry etc ...) with corresponding residual sugar levels and total acid levels. Schedule 2, table 2 sets out permissible alcohol levels (tops out for table wine at 14.9%).
Schedule 3 lists taste test assessment faults (only for VQA wines).
Schedule 4 sets out various fees.
Schedule 5, table 1 sets out permissible grape varietals for VQA wines other than aromatic sparkling which are in table 2.
In addition, the BC LDB (and other provincial liquor boards) require that any wine labels distributed in BC are approved by the Canadian Food Inspection Agency. The CFIA has an online guide to their wine labelling requirements here (see chapter 10 particularly).
The federal Food and Drug Regulations (see Division 2 on Alcoholic Beverages) also apply to all wines sold in Canada as do the provisions of the Consumer Packaging and Labelling Act. These include a requirement (see FDR B.02.108) to identify the country of origin for the wine contained in the bottle.
Please also be aware that if you intend to distribute your product outside Canada, there will likely be requirements in the destination country. For example, all wine sold in the U.S. must get label approval from the federal Alcohol Tobacco Tax & Trade Bureau (TTB).