On July 9th, President Joe Biden issued an executive order on promoting competition in the American economy. This can be very beneficial for the wine industry, it gives us the opportunity to evolve the winemaking process.
One problem in the US market that the executive order addresses concerns the approval of materials and processes used in winemaking. Although materials and processes are often approved for domestic use (27 CFR 24.250), they have not been updated to the export and domestic approved list (27 CFR 24.246) for over a decade. This has prevented winemakers from improving their winemaking process while reducing costs putting the US wine industry as a whole at a disadvantage.
Wineries in Europe and other countries are allowed to export wines to the US market that are treated with materials on 27 CFR 24.250, however, US wineries that export wine are particularly affected because they are restricted from utilizing items listed on 27 CFR 24.250.
WHAT YOU CAN DO!
The Treasury department and TTB have issued Requests for Information (RFI) to solicit input from wineries, breweries, and distilleries. This is your chance to help the wine industry innovate the winemaking process and help wineries increase their competitive advantage! You can submit a formal comment, but if you are representing a winery, we encourage you to upload a signed letter. The deadline for the submission is August 18th!
COMMENT EXAMPLE
“There are many great products that I would love to have the opportunity to use in my wines, but they are listed under the cfr 24.250 and so I cannot use them in wines subject to export. There is a chance that any of my wines could end up being exported so I am not able to utilize these advances. Wineries around the world are able to use these great tools which can help save time, and money. These new technologies can improve wine quality, increase winery sustainability and be healthier for consumers.
I would like to see products like vegan, and allergen free fining agents such as pea protein, and chitosan moved into the cfr 24.246 category so that I can produce vegan/allergen free wines, that can be exported. Vegan wines, as well as wines that do not contain allergenic materials are increasingly popular both in the domestic market as well as abroad. Currently the fining agents that are allowed are animal based and there is no plant based alternative available in the cfr 24.246. These materials work and have proven to be safe. It is really frustrating to be prevented from using effective tools that are a huge improvement over what is currently available. Wineries around the world use these tools and they export wines with these products in them into the US market. However, we do not have the same reciprocal opportunity. This clearly puts the US at a competitive disadvantage.
Please move everything from 24.250 to 24.246 so that all of the wineries in the USA have the same competitive advantage as wineries around the world.”