What, exactly, defines a wine as being from Pennsylvania? It seems like a relatively simple question. But if we dig into this, it quickly gets more complicated. For example, does “Pennsylvania wine” mean that it is produced in Pennsylvania? The fermentation, the aging, the bottling? Or does it mean the grapes are grown in Pennsylvania? Or does it mean both?

This is a particularly relevant question here (and in states with similar wine industries), because there are many wineries in the commonwealth — where the winemaking industry exists but isn’t quite as prominent as, say, California — who buy grapes from other places. (Urban wineries being one obvious example of this.) Sometimes these wineries buy actual grapes, but if they’re a little less advanced, they might just buy the juice, i.e., grapes that have been already been crushed and possibly macerated on the skins. (Which certainly represents a shortcut in the winemaking process.)

Laws around wine labelling, of course, can add clarity here. Unfortunately, they can also add quite a bit of ambiguity. But first, the former: at a high level, in order for winery to put ‘Pennsylvania’ on their wine label, the Alcohol and Tobacco Tax and Trade Bureau (TTB) requires that the grapes have been grown in the commonwealth, and that the wine has been “fully finished” in PA or an adjacent state. (There are number of exceptions regarding this “fully finished” statement, but since out-of-state wineries are not exactly lining up to use ‘Pennsylvania’ on their labels, we’ll ignore those for now.)

There is however, one major catch to this law, and it might just change everything.

Partially Authentic?

According to TTB regulation, to claim ‘Pennsylvania’ on a wine label, a minimum of 75% of the grapes must have been grown in-state. Which, in turn, means that as long as 75% of the grapes were grown here, 25% can come from literally anywhere else on earth. And while it doesn’t always, this 25% can become a massive loophole.

Consider, for example, a winery who wants to produce a varietal Cabernet Sauvignon, a grape that does not grow particularly well in the climate of Pennsylvania. (It struggles to ripen fully, to achieve that rich, full Cabernet Sauvignon flavor that people across the world know and love.) But it is a name people know, thus would probably sell well. This winery can, then, choose to add up to 25% of grapes from a warmer climate to help their wine find a more mainstream flavor profile.

In addition, because the requirements for varietal labelling are similar (to name a grape on the label, it must contain 75% of that variety), the 25% from elsewhere doesn’t even have to be Cabernet Sauvignon. So, as an example, this winery might be able to import Zinfandel from Central Valley of California, an extremely warm climate that is sure to produce grapes of incredibly high sugar (leading to high alcohol) and jammy fruit flavors. This Zinfandel, of course, would make a flabby, boring wine if produced varietally, but when mixed with grapes from a cooler climate, the resulting wine might just resemble a California-style Cab Sauv. (Not that it would be as great as the best Napa Cabs, but if it is pleasant to drink, it would be considered a success.)

So What?

Some wine drinkers might read read this and think: so what? If a producer is using a perfectly legal method to create the best possible wine, what’s wrong with that? Possibly nothing, though there are some potential downsides to consider:

The producer who brings in grapes from elsewhere is not required to put this on the label, so they can — even unintentionally — be presenting it as a fully local wine that isn’t actually. (Incidentally, if there is more than 25% of grapes from elsewhere in the US, the wine will be labelled as “American,” which is also commonly found on PA winery labels.)

Consumers who invest in local wine may be doing so for reasons beyond the wine itself, such as supporting the local economy, promoting agriculture and green spaces, creating jobs, etc. If a wine isn’t actually local, the positive impact one has by buying it will naturally be less. And if the producer doesn’t have to make this clear, the consumer may be easily misled.

Another important thing to consider the Pennsylvania wine industry itself. Looking at the great wine regions around the world, there’s always a strong identity. There is surely producer variation, etc., but generally there are certain grapes, styles and methods that become associated with the region that help the consumer understand what they are buying and open up opportunities for tourism, exports, etc.

When PA producers use grapes from elsewhere to mimic wines from elsewhere, however, it hinders industry progress. It gets in the way of learning about what grape varieties, growing techniques and cellar methods work best here. And it downplays any success that producers who are committed to creating 100% Pennsylvania wines might be having.

While adulterating PA wines to match more familiar styles might have a short-term value in terms of immediate wine sales, then, in the long term this harms the industry’s ability to develop both a cohesive regional identity as well as benchmark wines and styles that will ultimately boost sales and tourism across the entire state.

What Can We Do?

Unfortunately, because wineries are not required to label where grapes in the 25% came from, there’s not always a way to find out the exact makeup of any particular wine. When I speak to industry people, I often hear rumors — this winery uses this, that winery is doing that — but it would be irresponsible to share that information without actual evidence. I’m sure this is happening, but it’s tough to get proof when people aren’t always willing to admit it. (Though we can always ask!)

That said, when one tastes a red wine from Pennsylvania and it is jammy and rich, tasting like something from California, it’s highly likely that it is adulterated in some way. Whites are probably harder to spot, but might also display similar rich, bold fruit flavors. (Grape juice concentrate is another allowed method to make wines taste bolder than the place from which they came, but that’s another story for another day.)

Subzones FTW

Another important aspect of the PA wine industry — that may help here — is its American Viticultural Areas (AVAs). Essentially, AVAs are sub zones with particular characteristics that are regulated by the government, and have stricter requirements than state labels. (County labels, incidentally, essentially have the same requirements as state labels.)

In the United States, there are 269 recognized AVAs in 34 states (as of August 2023), including famous ones like Napa Valley, Sonoma Valley and Willamette Valley, and there are five in Pennsylvania (several of which are shared with other states). The AVA system is basically the American version of the DOC/G in Italy or AOC in France; as such, almost every bottle of famous wine in the world will have the local version of an AVA on its label, e.g., Bordeaux, Barolo, Chianti, etc.

While we could probably talk quite a bit about all the complexities of AVAs, there are two things to know, at a very basic level, about why they are important. Firstly, AVAs further delineate the differences between different regions. Pennsylvania is a large state. It’s not as large as California of course, but the Lehigh Valley, for example, has different microclimates when compared to Lake Erie, which is several hours away by car. (In Italy, one who drives for several hours might cross dozens of these subzones!) So there could be quite a difference in the styles of wine across these two regions.

The second thing to know about AVAs is that they have stricter rules about where the grapes come from, in this case requiring 85% to be grown within the specified AVA. So while there is still some limited ability to adulterate, it is less so than with state labels. Those 10 percentage points, in other words, help ensure a wine is more strongly associated with the place where its grapes were grown.

Again, if we as a state want to build identity, if we want to build knowledge about what these regions have to offer, leaning on these AVAs more (and creating new ones) could be a great opportunity for the Pennsylvania wine industry

Wrapping Up

It does seem somewhat unfair, of course, to judge a winery making wine in a legal way without fully understanding the entire picture. We don’t know their business, and why they make certain decisions. That said, we here at PAVC aim to be consumer advocates, and believe that helping consumers better understand what they are buying, and what that might mean for the PA wine industry. We hope it was helpful.

Lastly, if you work in the wine industry and feel that any of the laws were presented incorrectly here, please let us know. Interpreting TTB guidelines is not exactly straightforward!