If the craft cider in a bottle can change its character over time, then it is in the interests of the consumer, the retailer, and the producer to know the vintage date of the apples that went into making the cider.
More importantly, if the concept of terroir applies to cider in the same way as it applies to wine; that is, if soils, aspect of the land, the climate and the specific weather during a growing season impact the quality and character of the apples that go into making the cider, then having a vintage date on a bottle of cider is very important information.
Yet, the Alcohol and Tobacco Tax and Trade Bureau (TTB), which regulates the labeling of ciders measuring over 7% alcohol, prohibits the use of a vintage date on ciders. This regulation isn’t so much a comment by the TTB on the nature of cider as it is a strict interpretation of the TTB’s rules and regulations which, in Title 27, Chapter I, Subchapter A, Part 4.27, read like this:
“Vintage wine is wine labeled with the year of harvest of the grapes and made in accordance with the standards prescribed in classes 1, 2, or 3 of §4.21. The wine must be labeled with an appellation of origin.”
What’s important to note here is that there is no mention of cider. You’ll read no prohibition on placing a vintage date on cider, but you don’t see “cider” listed alongside “wine” as being “labeled with the year of the harvest…”
For the serious producers of craft cider as well as for serious cider lovers, a change in these TTB rules and regulations to allow cider labels to wear a vintage date would be a substantial improvement. And perhaps equally important, such a change would signal recognition of the vibrancy and development of the craft cider sub-culture.
However, such a change in the labeling rules could be complicated. You’ll note in the rule quoted above the insistence that “The wine must be labeled with an appellation of origin.” This is important because unless you note where the apples were grown, just as unless you note where the grapes were grown, then the matter of the vintage is unimportant because you can’t determine what the weather during the growing season was like, nor the impact it may have had on the apples or grapes, since without an appellation of origin on the label you don’t know where on earth to look for information on the growing season.
The problem is that unlike with wine, there exists no Appellation of Origin system for apples.
If an effort to change TTB regulations to allow a vintage date on cider labels is undertaken, then a simultaneous effort must be made to establish some sort of appellation of origin system for apples.
This could most easily be accomplished by requiring any cider with a vintage date on the label to also list on the label the state in which the apples were grown. While a state-based appellation system covers a lot of territory, it would deliver some context for the vintage date and it’s notable that in the wine industry, the state may be used as the appellation of origin if a winery chooses.
Additionally, a much more geographically specific county-based appellation system could also be implemented to give the vintage date context. And, again, it’s notable that wineries may also choose to only place a county name on their label to identify where they grew the grapes that went into make the wine.
Another even more intriguing option for creating an appellation system for cider to accompany vintage dating is to simply adopted wholesale wine’s American Viticultural Area (AVA) system that currently provides federal recognition for over 200 wine growing regions across the country.
In order for a proposed AVA to be approved by the TTB, petitioners must show that certain growing conditions in the AVA, such as climate, soil, elevation, and physical features, are distinctive and that the borders of the AVA legitimately encompass and contain these features. There is no requirement that a proposed AVA have any particular advantages specific to growing wine grapes. The “Napa Valley”, “Sonoma Valley”, “Walla Walla and all other AVAs were created not because wine grapes grew well inside these particular AVAs, but because the grapes grown inside these AVAs were impacted by distinctive geographic and climatic factors. Apples grown in these AVAs would be impacted by these same conditions.
No matter what type of boundaries would define a cider appellation system, there is no question that changing TTB rules to allow vintage dates on cider is an important project for craft cider producers to pursue. Any craft cider producer that makes cider from the same orchard year after year or from the same region year after year will tell you that each year their cider is different. Perhaps the weather allowed the apples to get riper faster. Perhaps a cooler growing season meant apples didn’t get quite as ripe and had lower sugars. Perhaps different levels of alcohol, acid and tannins in the apples one years conspire to allow that cider to age in the bottle more elegantly and become something unique 5 years after bottling. There are myriad reasons to vintage date cider.
But the most important reason to allow vintage dating on ciders is that by placing a vintage on the label alongside a designated appellation, you identify the product in the bottle as something unique; something that represents a time, place and the maker’s ambitions. The vintage date and appellation identifies the cider as a craft product, something the most dedicated cider producers already know they are making and something more and more cider drinkers want.