How Sonoma County Wineries Can Skirt the Law

sonappellationBeginning yesterday, January 1, 2014, any wine released that will identify any American Viticultural Area (AVA) on the label located inside Sonoma County MUST also carry the words “Sonoma County” on the label.

I’ve noted in a number of blog posts why this is a very bad idea. This made no difference and the “Conjunctive Labeling Law” for Sonoma County is now in force. Vintners in the Russian River Valley, Alexander Valley or Bennett Valley, for example, who see no value in putting “Sonoma County” on their wines’ labels must do so. And those vintners that place “Sonoma Valley” or “Sonoma Coast” on their wines’ labels must live with the aesthetic indignity of also putting the words “Sonoma County” on their labels.

For these vintners, the question now becomes how to mitigate the impact of this new law on their labels and marketing by using legal means to skirt the intent of the law. I have some suggestions.

First, it’s important to note that the actual law that passed the California State legislature specifically says that any wine carrying the name of an appellation inside Sonoma County:

“shall bear the designation ‘Sonoma County’ on the label in a type size not smaller than two millimeters on containers of more than 187 milliliters”

Note that the law does not say on which label on the container the words “Sonoma County. Traditionally, wines have at least two labels on them: The Front (which tends to face forward on store shelves) and the back (which is usually unseen when on store shelves. It appears that vintners may bury the words “Sonoma County” on any part of the bottle. IMPORTANTLY, this seems to mean that the term “Sonoma County” need not appear anywhere near the name of the appellation the vintner actually wants to put on their label. This loophole will allow vintners who produce “Sonoma Coast” wines from having to confuse customers by placing “Sonoma County” directly next to the more accurate “Sonoma Coast” wording. The same can be said for those vintners who bottle “Sonoma Valley” or “Sonoma Mountain” wines.

Regarding prominence and legibility of the term “Sonoma County”, the law also seems to suggest that the words merely be two millimeters high. Professional graphic designers, given this criteria, should be expert in finding ways to absolutely bury this useless term somewhere on a back labels of a wine so that the likelihood of a consumer buying a Dry Creek Valley Zinfandel or a Chalk Hill Chardonnay being confused by it is significantly lessened. 

Prior to the Sonoma County Conjunctive Labeling Law coming into legal force, a vintner could, if they chose and if they believed it beneficial, place the term “Sonoma Valley” prominently on their label. Few who could actually claim a more specific Sonoma County-based appellation did this, for obvious reasons. Now that option is gone.

For Sonoma County-based vintners who actually care about their marketing and their marketing and brand, who believe that promoting more specific and smaller and meaningful appellations is more important and more beneficial or who simply oppose subsidizing the marketing of the primarily larger wineries that use Sonoma County on their labels, today the work begins on skirting this new law.


8 Responses

  1. Rex Stults - January 2, 2014

    Interesting commentary Tom. The conjunctive labeling law for Napa County, which goes back to 1990, requires “Napa Valley” to appear anywhere and everywhere on a wine bottle that a nested appellation of Napa Valley appears. That info comes via a letter of interpretation from chief counsel of ABC, enforcers of the law.

  2. Tom Wark - January 3, 2014

    Rex:

    It won’t surprise me if at some point a LoI comes down from the ABC, TTB or CA AG that requires the same. At this point however, there is no such thing. I’d also note that Napa Valley and Sonoma County possess two entirely different geographic characters. In the end, the new Sonoma County equity law is a equity swap whereby those wineries that have built meaning and value around the sub-appellations are forced to swap that good will for the—how shall we say—lesser good will of the “Sonoma County” brand.

  3. Pat F - January 3, 2014

    It must be a typo that states”Vintners in the Russian River Valley, Alexander Valley or Bennett Valley, for example, who see no value in putting “Sonoma Valley” on their wines’ labels must do so.” did you mean Sonoma county?

  4. Tom Wark - January 3, 2014

    Pat, indeed it was a typo and now fixed. And yet, the typo itself reminds us just how confusing this new conjunctive labeling can potentially be. Thanks!

  5. The Drunken Cyclist - January 3, 2014

    Pardon my ignorance, but what is the other side of this issue? It seems so non-sensical to me in a wine-savy state like California. I could understand a less well-known region (e.g., my own state of PA) adopting such a law in order to increase overall awareness (or some such nonsense). But Sonoma? I just don’t get it.

    (By the way, the same inadvertent use of “Sonoma Valley” instead of “Sonoma County” that Pat pointed out appears to have occurred in the next to last paragraph as well.)

  6. John Skupny - January 3, 2014

    The issue has never been confusing to me – makes perfect sense and operates in the best interest of vintners and consumers, here in Napa Valley – It is just a shame this law was not considered 30 years ago for Sonoma – Ok, Ok, I know a Pauillac does not necessary say Bordeaux – but maybe it should, it is their loss – education and understand do help in the bigger picture

  7. Patrick Shabram - January 3, 2014

    A conjunctive labeling requirement by the TTB would be very unlikely as it would be somewhat defeating of the purpose of recognizing AVAs. That being said, the TTB has become much more vigilant in using unique rather than common names in newer AVAs. Names like “Dry Creek” and “Chalk Hill” wouldn’t fly today. If a more common name is being used, a broader identifier is required. Such was the case with the recently recognized Moon Mountain District Sonoma County. There are several Moon Mountains across the country, and the TTB wanted a geographic identifier to distinguish this Moon Mountain from others. That adds another level of complexity to the conjunctive labeling requirement. Imagine conjunctive labeling of “Moon Mountain of Sonoma Valley” with “Sonoma County.” At the end of the day, it just made sense to add Sonoma County to the federally recognized AVA name, thereby killing two birds with one stone.

  8. Kristina Panfilova - January 5, 2014

    I think it is a good idea. We live in Los Angeles and rent a vacation home in the Forestville area every year. We tell everyone that we are going to Napa Valley. Why? Most of the non-wine people (in Los Angeles!) don’t know where Sonoma Valley or Sonoma County (or Russian River) is. It’s very good for its wines, isn’t it?


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