The concept of wine varies widely among winemakers. At one end of the scale, wine is made by passionate small producers who value 'naturalness' and 'purity' above all else. In this view, every additive and processing aid is a deviation from the ideal, and they will be avoided even if they make the wine taste better. If an exception is made, it is likely to be for sulphur dioxide because without this additive the wine simply is too prone to spoilage.
At the other end of the scale, one only needs to consider that the bulk of wine is cheap, consumed uncritically and produced in millions of litres by vast corporations. It is not surprising that these winemakers would adopt any and all additives and processing aids (and production technologies) that allow them to make wine more cheaply, safely or efficiently. This is what we expect when we buy any other mass-produced processed food, so why not wine?
So, if the code is constantly being amended to allow more and more additives, then this is shifting the regulation of winemaking in favour of the mass-produced product and away from the natural and pure product. In reviewing the most recent changes to the code (below) it seems to me that this is simply being allowed because winemakers either don't care or aren't paying attention.
The code changes when some proponent, typically WFA or an additive manufacturer, makes an application. The application is assessed by Food Standards Australia New Zealand (FSANZ), and this assessment includes a call for public comment. Very few winemakers take this opportunity, either out of ignorance, apathy, or not wanting to antagonise other winemakers. FSANZ bases its decision on considerations of safety and public benefit. What is not considered by FSANZ is protecting the natural and pure concept of wine, because of course that is not their job. I think it is time for those who value wine as a natural product to start defending it. The horse has bolted but it is still in sight.
It is worth keeping in mind that this blog only considers regulation of Australian wine production. Other wine producing countries allow their own set of additives and processing aids, and some of those lists are even longer than ours, and the wines are legal for sale in Australia.
Here are the most recent changes to the code that altered the additives and processing aids that may be used (with my subjective comments):
|Recent history of amendments to Food Standards Code 4.5.1|
|Amendment 127, November 2011||Sodium carboxymethylcellulose became a legal additive, intended for use in cold stabilisation. Already, suppliers are aware of it being used for mouthfeel rather than for cold stabilisation, hardly surprising considering this is an established use of CMC in other beverages.|
|Amendment 126, October 2011||The minimum alcohol content of wine became 4.5% (by volume). Previously it was 8% and products below this level had to be labelled as something else such as ‘wine product’. In practice, wines below 8% such as some moscato styles were being illegally labelled as wine. To make wine at alcohol levels as low as 4.5%, either there is extensive de-alcoholisation by a technological process such as reverse osmosis, or the wine contains a high level of residual sugar.|
|Amendment 122, May 2011||Previously, subclause 5(5) of the standard limited the PVPP content of wine to 100 mg/L. By removal of reference to PVPP in this clause, the limit is ‘Good Manufacturing Practice’ which is specified in the more general Food Standards Code 1.3.3 which applies to all foods.|
|Amendment 98, May 2008||Yeast mannoproteins became a legal additive. The application was made by Laffort, a supplier of winemaking additives and processing aids. The assessment report describes the intended use of yeast mannoproteins as ‘to inhibit the formation of potassium bitartrate crystals’. However, Laffort now market four products to winemakers in Australia, only one of which is specifically intended to inhibit the formation of potassium bitartrate crystals, the others are advertised to contain also polysaccharides and mannoproteins with high sapid peptide content, and having benefits such as ‘Acts on the wine palate influences, increasing softness, roundness and length’ or ‘Provides an increase of sweetness sensations with a concurrent decrease in tannin aggressiveness (through a light fining effect)’ or ‘Decreasing aggressive sensations (fining effect) [and] Increasing sweetness sensations’.|
|Amendment 94, October 2007||Changed the permitted processing aid from ‘cupric citrate on a bentonite base’ to the more general ‘cupric citrate’.|
|Amendment 92, August 2007||'To ... permit additional water to be present in wine for technological purposes and in conformance with good manufacturing practice.' Previously a limit of 3% was placed on water addition during winemaking, but this amendment raised it to 7%. Water is typically added when required to dissolve or suspend additives and processing aids. Water can also be added as a consequence of pipes, hoses and equipment having been flushed with water prior to wine transfer. The application by the Winemakers Federation of Australia asserted that the 3% limit was insufficient for these needs, and there was a precedent for a 7% limit in an agreement between Europe and the US. In my calculations, even as a small winemaker where the danger of water additions would if anything be larger, it is unlikely that normal winemaking practice would require even the 3% limit. The extension to 7% simply gives legitimacy to the industrially-minded winemakers who use dilution with water when it is convenient to do so.|
|Amendment 73, August 2004||Collagen (an animal protein) is permitted by this amendment as a processing aid. Collagen is the protein from which the already-permitted processing aid gelatin is derived.|
|Amendment 72, May 2004||This amendment changed the title of the Australian wine production standard from 4.1.1 to 4.5.1 as well as introducing a number of substantive changes: carbon dioxide and gum arabic were added to the table of permitted additives, the permitted additive 'uncharred oak' was replaced with the broader processing aid 'oak', and argon was added to the list of permitted processing aids.|
|Amendment 70, April 2004||Plant proteins were allowed as processing aids due to fears about the potential for BSE from animal-derived proteins, and also recognising the potential to make wine with fining agents that are acceptable to vegans. Cupric citrate on a bentonite base was added as a permitted processing aid following the application from Swift & Co, manufacturer of such a product. Copper sulphate is already a permitted processing aid.|
I've never used any of the additives or processing aids allowed by these most recent amendments, nor do I see any reason why I would, so I hardly feel that I am benefited by them. FSANZ has ensured that the changes preserve the safety to consumers of wine consumption. However, nobody has ensured that wine will continue to be perceived as a natural product, and the list illustrates that we're clearly not moving in that direction.