The Directorate-General for Agriculture and Rural Development of the European Commission (DG Agri) has rejected the term ‘natural wine', deducing its hypothetical deceptiveness. A Pyrrhic victory for the lobbyists of the large wine industries, as the natural wine market continues its growth unstoppable growth, also in Italy, regardless of the use of this or similar terms.
It will therefore not be a name, on the label and in advertising, to testify the efforts of operators who cultivate vineyards without agrotoxics and produce wine without aids and chemical additives. Rather, it will be the blockchain, the QR-code and the apps – that is, collective brands associated with specific guidelines – to communicate and express the values of wines produced according to nature. As consumers increasingly demand.
Wine, the lobby of silence and pesticides
The CEEV (Comité Européen des Entreprises Vins) is the lobby European association of wine producers. And it is one of the most powerful, as demonstrated by the shame of the unjustified exemption of alcoholic beverages from the obligation to indicate ingredients and nutritional values on the label. To the point that it is still admitted today that major producing countries like France and Germany continue to hide legal adulteration of must with sugar (so-called sweetening). It is precisely CEEV that advocates silence about the composition of alcoholic beverages, as well as various tricks such as ‘wood in the wine’ on bottles with Protected Geographical Indication (PGI).
The lobby of wine has always been aligned with COPA-COGECA – the European confederation of agricultural confederations, dominated by Coldiretti – which on 20.10.20 sank the ecological transition project of the CAP (Common Agricultural Policy). And it is closely linked to the Big 4, the global pesticide monopolists who find their largest market in conventional vineyards. It is no coincidence that in Prosecco-shire, as we have seen, the consumption of agrotoxics represents 625% compared to the European average. And this explains the fury towards natural wine.
Natural wine, Brussels at the service of lobbyists
The big industries – those that control every representative organization, with the power of membership fees – have decided to oppose the extraordinary market phenomenon of natural wines, incompatible with the financial logics that guide their businesses. CEEV therefore submitted a 'question' to DG Agri on 15.4.20, aimed to challenge the use of the term ‘natural’ as well as terms like ‘vin nature’, ‘vin méthode nature’ in the labelling and presentation of certain Bacchus nectars.
The European Commission has responded to lobbyists’ requests in its 7.9.20 letter replying to CEEV. (1) The Brussels institution thus stated that the adjective ‘natural’ could be able to create in consumers the expectation of a product of superior quality and ‘healthier’ than ‘common’ wine, suggesting substantial differences in its composition and nature.
Instrumental arguments
DG Agri has entrusted its evaluations to a restrictive interpretation of the applicable European regulations. Using arguments instrumental to the thesis proposed by CEEV:
– the category ‘natural wine’ is not included among the categories of wine products listed in Annex VII, Part II, of EU Reg. 1308/2013 (the so-called Single CMO). Although no independent winemaker, as far as is known, has requested the modification of the Common Market Organization regulation,
– ‘Wine is the product obtained exclusively from the total or partial alcoholic fermentation of fresh grapes, crushed or not, or grape musts’. (2) It is therefore legitimate to use the denomination ‘wine’ for products known as natural wines,
– ‘authorized oenological practices are used only to allow good winemaking, good preservation or good aging of the products’. (3) And needless to say, it is worth adding. Although, as is obvious, such a broad definition of the objectives for the use of authorized technological aids and food additives leaves free rein to the imagination of the most daring winemakers.
Are all wines the same?
The bureaucrats in Brussels therefore deduce that ‘all authorized practices in the EU are such as to 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) – still not mentioned on most labels – did not affect the composition of the product (and the safety of its consumption by allergic consumers). Or if the quantities of sulfur dioxide and sulfites were irrelevant, without needing to mention other substances such as synthetic tartaric acid.
The height is the statement that any product could be marketed as ‘natural wine’, provided that the denomination ‘wine’ is respected, ‘regardless of the authorized oenological practices used in its production and the fact that oenological practices have been used.' This, we add, would be misleading information. Where organizations exist, such as VinNatur, which have defined very strict regulations and analysis criteria.
Consumer information
The officials of DG Agri then ventured into a topic beyond their expertise, the Food Information Regulation (FIR). For a sterile reference to the general criteria of transparency and non-misleading information to consumers concerning food products, defined in Article 36 of Regulation EU 1169/11.
The use of the term 'natural’ associated with a wine would by itself be suitable, for the lobbyists' lackeys, to deceive the consumer and 'interfere with their rights to objective information'. But this is like debating the sex of angels, since clarity and transparency of consumer information must instead be evaluated case by case. And one cannot doubt the correctness of those who show (and can demonstrate) objective rigor, for example, by excluding chemical weed control and other agrotoxins from vineyards and certain enological practices.
Legal implications
'This opinion is provided based on the facts exposed in your letter [from CEEV, ed.] dated April 15, 2020, expresses the point of view of the Commission services and does not bind the European Commission.' DG Agri does not even dare to share its theses with other Directorates-General such as Sante, Grow and Competition. And it recalls, as it must, that the only official interpretation of EU law is that offered by the Court of Justice of the European Union.
The winemakers who intend to designate their wines and related production methods as 'natural' must only specify exactly the meaning of such labels. Offering clear communication to consumers, as established by Regulation (EU) 1169/11. Precisely on these bases, the French authorities have already recognized the legitimacy of using the label vin naturel. These products are appreciated, among other things, also because they are metabolized better than conventional wines. And this is the only information that cannot be displayed on the label, although certified in a recent scientific study.
Dario Dongo and Silvia Giordanengo
Cover image: Pur Jus. Cultivons l’avenir dans les vignes, by Justine Saint-Lô and 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, on https://news.unioneitalianavini.it/wp-content/uploads/sites/6/2020/09/reply_to_ceev_on_the_labelling_indication_natural_wine_20200907.pdf
(2) EU Reg. 1308/2013, Annex VII (Definitions, designations and sales denominations of the products referred to in Article 78), Part II (Categories of wine products), point 1
(3) EU Reg. 1308/13, Article 80 (Winemaking practices and methods of analysis), paragraph 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.
