Chitosan, the latest addition

It has happened to me again that a sales rep has come trying to sell me a wine additive product, and I returned to the blog to see if it is in fact legal. Last time this happened, with CMC, it wasn't (i.e. they were selling it before it had been added to the list). This time, it is legal, just the blog was out of date. So here is the latest addition. And yes, I am tired of seeing more and more additions, but that was the topic of my last (and sorry, not very recent) post.

Latest amendment to Food Standards Code 4.5.1

Amendment 145, January 2014

Allowed the use of fungal chitosan from Aspergillus niger as a processing aid for a number of purposes including as a fining and clarifying agent in the manufacture of wine, beer, cider, spirits and food-grade ethanol. The product that is being promoted to me is a mixture of chitosan and pectinase and glucanase enzymes, intended to facilitate the lysis and elimination of Brettanomyces, a spoilage yeast. So, chitosan may be a partial subsitute for sulphur dioxide.

Who is adding to the additives and why?

One of the things that interests me about wine additives is how it is exactly that more and more are being allowed. Never once as a winemaker has anyone asked my opinion whether another additive should be allowed, yet some of the applications for changes to the code originated from the so-called peak wine industry body, Winemakers Federation of Australia (WFA), of which I was a member. Never once have I observed any discussion in the wine community of the merits of another addition to the code. Yet, the constant addition to the code is changing the nature and perception of the product so many of us care so deeply about.

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.

Labelling debate

Some interesting thoughts on this US site regarding the pros and cons of ingredient labelling for wine. While we're at it, another good article from the US.

Weird stuff

You could spend a lot of time figuring out if published information is nonsense or not. Today I came across a US website claiming that titanium dioxide, which is used to make rubbish like marshmallows look really white, is also used in wine. It certainly isn't used in wine in Australia, but who knows what they get up to in other countries? While I haven't spent a lot of time, I did find an interesting paper by Vashti Christina Galpin, comparing wine legislation in a number of countries. No mention of titanium. Funnily enough, that paper also directed me to a page on our own AWRI website that allows searching of allowed additives in most wine-producing countries. Again, no evidence for anyone using titanium dioxide in wine.

Carboxymethylcellulose update

Back in June I looked at the latest application to add an additive to the list allowed for winemaking in Australia. Sodium carboxymethylcellulose (CMC for short) has subsequently been approved for use as an additive, the change to Standard 4.5.1 taking effect with gazettal on November 17th. The story appeared today in the Australian under the surprising headline 'Nod for laxative chemical to be used in winemaking'. CMC does indeed have laxative properties (Schultz, 1949). It would be interesting to compare the laxative dose with the concentration to be used in wine. I've now updated the additives table with the inclusion of CMC.

Wine additives in the news

Chris Shanahan, wine columnist for the Canberra Times, wrote an article 'Wine additives play a part' which appeared yesterday. It can be read online here. While the subtitle was 'Why you don't have to be alarmed about the additives in your wine', some of the comments so far are from people who are unnecessarily alarmed. I understand that additives in food can be emotive, but that is exactly why this blog exists – so that you can know what the additives are for and whether they are worth being alarmed about or not.

Wine ingredient labelling

Currently, wine and other alcoholic beverages are exempt from the requirement to label ingredients. However, wine additives and processing aids include some for which declaration is mandatory when they are added to any food. Those relevant to wine are:

• 'Egg and egg products'.
  Would be labelled where the processing aid egg white has been used in fining, or lysozyme (purified from egg white) has been used to control bacteria.
• 'Fish and fish products'.
  For a period it was necessary to label these on beer and wine, when the processing aid isinglass had been used, until an exemption was granted in 2009. This decision was made because isinglass contains very small amounts of the fish allergen parvalbumin, and of this, any amount remaining in the final product is undetectable and would not be expected to cause an allergic reaction in fish-allergic consumers.
• 'Milk and milk products'.
  Would be labelled where the processing aid milk has been used in fining.
• 'Added Sulphites in concentrations of 10 mg/kg or more'.
  See the additive sulphur dioxide.
• 'Tree nuts and sesame seeds and their products other than coconut from the fruit of the palm Cocos nucifera'.
  Would be labelled where the additive tannin has been added and includes material from nuts such as chestnut.

So, wine additives are not labelled, except for these allergens. Should all ingredients be labelled in wine, as they are for other foods? Max Allen asked this question of his readers recently, and will be writing more on the topic soon.

Brtish wine authority Jancis Robinson came out in favour of labelling in a recent article in Gourmet Traveller WINE, and a longer version may be read here. (Note that the article includes the image of a Chilean back label that includes carboxmethyl cellulose among its ingredients.) The article is out of date, incidentally, in suggesting that Australian wine regulations still require the labelling of ascorbic acid or fish products (see above).

Robinson argues for labelling "not for health reasons but because I think curious wine drinkers are justified in wanting to know how their wines were made". After discussing a number of specific ingredients, she concludes that "...as a purist, idealist wine lover, I would dearly love to know which wines had been most manipulated and reward the rest with my, perhaps naïve but extremely heartfelt, admiration. Who knows? If ingredient labelling were to become mandatory for wine as well as food, it might just encourage winemakers to use fewer shortcuts and additives."

What do you think?