Organic Wine Certification

Organic wine begins in the vineyard: it is wine made from grapes grown in vineyards that exclude synthetic chemical fertilizers, herbicides, fungicides and pesticides, apart from substances the US National List or the EU authorisation lists allow. The rules then follow the wine into the winery. In the US, wine in the 'organic' and 'made with organic grapes' labeling categories must be overseen by an accredited certifying agent, who verifies that the wine meets the USDA organic regulations. In the EU, products of the wine sector must be produced from organic raw material, and only products and substances authorised for organic production may be used in making them, including during oenological practices, processes and treatments.

• In both the US and the EU, certification covers winemaking as well as grape-growing.
• In the US, ingredients produced with prohibited methods such as genetic engineering are not allowed in 'organic' or 'made with organic grapes' wine.
• In the EU, GMOs, products produced from GMOs and products produced by GMOs may not be used in organic production.

In the US, any use of the term 'organic' on a wine label or in wine advertising must comply with the USDA National Organic Program rules (7 CFR part 205), alongside TTB's wine labeling rules in 27 CFR part 4. Wine labeled 'organic' may not contain sulfites added during production or handling; it may contain only naturally occurring sulfites, less than 10 ppm. Yeast must be certified organic unless the desired strain is not available in organic form, all agricultural ingredients such as grapes must be certified organic except as the National List allows, and non-agricultural ingredients must be on the National List and may not exceed a combined 5 percent of the total product (excluding salt and water). An 'organic' wine may carry the USDA organic seal anywhere on the label. Wine containing added sulfites may be labeled 'made with organic grapes': sulfur dioxide is allowed only in wine labeled that way, provided total sulfite concentration does not exceed 100 ppm, and the added sulfites must be disclosed on the label. All grapes must be certified organic, but other agricultural ingredients such as yeast are not required to be organic, and the USDA seal may not appear. A wine that fits neither category, for example one with both organic and non-organic grapes or with sulfur dioxide above 100 ppm, is not eligible for organic certification; it may identify certified organic ingredients in its ingredient statement, but it may not use the seal, and all other organic claims are prohibited.

• 'Organic': no added sulfites, USDA organic seal allowed.
• 'Made with organic grapes': sulfur dioxide up to 100 ppm, no USDA seal, and the claim in letters no more than half the size of the largest type on the panel.
• Labels in both categories name the certifier ('Certified organic by') below the handler or distributor; the certifier reviews and stamps the label before it goes through TTB's Certificate of Label Approval (COLA) process.
• TTB requires a 'Contains sulfites' statement when sulfur dioxide is detected at 10 ppm or more, measured as total sulfur dioxide; any statement that a wine contains only naturally occurring sulfites requires a lab analysis.
• US wine labeling rules (27 CFR part 4) allow finished wine to contain up to 350 ppm of total sulfur dioxide without that treatment altering its class or type.

In the EU, organic production is governed by Regulation (EU) 2018/848, which applies from 1 January 2022 and repealed Regulation (EC) No 834/2007; its wine-sector rules sit in Article 18 and Part VI of Annex II. Unlike US 'organic' wine, EU organic wine may contain added sulphur dioxide, within lower limits than conventional wine. Under Implementing Regulation (EU) 2021/1165, the maximum sulphur dioxide content is 100 mg/l for red wines and 150 mg/l for white and rosé wines, each with residual sugar below 2 g/l; for all other wines, the conventional maximum is reduced by 30 mg/l. The conventional benchmark in Delegated Regulation (EU) 2019/934 is 150 mg/l for red wines and 200 mg/l for white and rosé wines (other than sparkling and liqueur wines) with sugar below 5 g/l, raised for wines with 5 g/l of sugar or more. On the label, terms referring to organic production may be used only for products that comply with the regulation, and the code number of the control authority or control body for the operator that carried out the last production or preparation operation must appear. The EU organic logo must also appear on the packaging of prepacked food, except in the cases referred to in Article 30(3) and points (b) and (c) of Article 30(5), and may be used on compliant products; where it is used, an indication such as 'EU Agriculture' or 'non-EU Agriculture' appears in the same visual field. Products produced during the conversion period may not be labelled or advertised as organic or as in-conversion products, except that plant reproductive material, food products of plant origin and feed products of plant origin that comply with Article 10(4) may be labelled and advertised as in-conversion products.

• Organic maximums: 100 mg/l for red, 150 mg/l for white and rosé (residual sugar below 2 g/l); all other wines: the conventional maximum minus 30 mg/l.
• Conventional maximums: 150 mg/l for red, 200 mg/l for white and rosé (sugar below 5 g/l).
• Winemaking: only products and substances authorised for organic production may be used, and heat treatments may not exceed 75 °C.
• History: Regulation (EU) No 203/2012 applied from 1 August 2012 and set detailed EU rules on organic wine; under it, for stocks of wine produced until 31 July 2012, wine labelled 'wine made from organic grapes' could not bear the EU organic logo.

USDA has trade partnerships with multiple countries that allow organic products certified in one country to be sold as organic in the other, but traded products must meet the labeling requirements of the destination country. A wine produced and sold in a foreign country therefore typically has a separate label if it is also imported to the United States. An EU organic wine with added sulfites (more than 10 ppm) is not eligible for the US 'organic' category and cannot carry the EU or USDA organic seal in the US; the EU organic logo comes off the US label, and the wine may say 'made with organic grapes' instead. In the US, a wine with added sulfites cannot be labeled 'organic': at most it is a 'made with organic grapes' wine. Decanter has described unsulphited organic wines as rare because of their short shelf-life in bottle.

• Destination-country labeling rules apply to traded organic products.
• An EU organic wine with added sulfites can be 'made with organic grapes' in the US, without the EU logo or the USDA seal.
• The US label must spell out the certifier's full name ('certified organic by'), not just the code assigned in the EU.

US organic rules start with prevention: growers must use management practices to prevent pests, weeds and diseases, including sanitation and the selection of plant species and varieties suited to the site and resistant to prevalent pests, weeds and diseases. Pests may be controlled by introducing predators or parasites of the pest, developing habitat for natural enemies, and nonsynthetic lures, traps and repellents; weeds by mulching, mowing, livestock grazing, hand weeding and mechanical cultivation, or flame, heat or electrical means. When these practices are insufficient, a biological or botanical substance, or a synthetic substance on the National List, may be applied, with the conditions documented in the organic system plan. Soil fertility is managed through rotations, cover crops and plant and animal materials; fertilizers containing a synthetic substance not on the National List, and sewage sludge, are not allowed. For crop disease control, the National List allows elemental sulfur, lime sulfur, fixed coppers and copper sulfate, with copper used in a manner that minimizes accumulation in the soil. In the EU, where plants cannot adequately be protected by preventive measures, only products and substances authorised for organic production may be used, and only to the extent necessary. The EU authorised list includes sulphur, lime sulphur and copper compounds, with copper uses limited to a total of 28 kg per hectare over 7 years (on average 4 kg per hectare per year), a restriction that applies from 1 January 2019.

• US and EU rules both put preventive practices first and allow listed inputs only when they are needed.
• Sulfur: elemental sulfur and lime sulfur (US National List); sulphur and lime sulphur (EU authorised list).
• Copper: US fixed coppers and copper sulfate, used so as to minimize copper accumulation in the soil; EU maximum of 28 kg of copper per hectare over 7 years.
• Organic growers counter vine fungal diseases such as mildew with sulfur dust or copper sulfate.

In the US, USDA authorizes third-party accredited certifying agents to assess organic operations' compliance with the USDA organic regulations; a certifying agent is any entity accredited by the Secretary of Agriculture for that purpose. Knowingly selling or labeling a product as organic, except in accordance with the Organic Foods Production Act, carries a civil penalty. The Strengthening Organic Enforcement final rule, published on 19 January 2023, amended the USDA organic regulations to strengthen oversight and enforcement of the production, handling and sale of organic products; its topics include exemptions from organic certification, National Organic Program Import Certificates and product traceability. In the EU, the label carries the code number of the control authority or control body. Organizations such as the Soil Association in the UK and Ecocert in France award organic certification. Biodynamic certification builds on organic: a biodynamic grower must follow the organic criteria plus some or all of the philosophies of Rudolf Steiner, and bodies such as Demeter grant a certificate to those reaching the criteria. Conversion takes time. In the US, land must have had no prohibited substances applied for 3 years immediately preceding harvest of the crop; in the EU, perennial crops other than forage must be farmed under the rules for at least three years before the first harvest of organic products.

• US: accredited certifying agents oversee organic wine, and the certifier is named on the label.
• EU: the control authority or control body code number appears on the label.
• Conversion: 3 years without prohibited substances before harvest (US); at least three years before the first organic harvest for perennial crops other than forage (EU); EU conversion-period products cannot be labelled organic.
• Demeter certifies biodynamic growing, which builds on the organic criteria.

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