"Organic" But Not Certified

I was recently looking online for grapes for the 2020 harvest. I found some, on a popular wine industry site, listed under an "organic" keyword search, but when I contacted to ask for more info they sent me the below graphic, with this email:

"I know farmers at xxxxx aim to use as many organic implements as possible throughout the growing season as the owners live on the property with their children."

Example of a conventional vineyard treatment that was called "organic" but clearly is not.

Example of a conventional vineyard treatment that was called "organic" but clearly is not.

It's a nice graphic, but clearly lists pesticides - such as Luna Experience, Quintec, and Flint - which are not OMRI listed for organic use. If you use even one of them you cannot say the grapes are "organic." That's black and white. They used at least three.

So why did this Santa Barbara winegrower advertise grapes for sale under the keyword "organic?" When I let them know I wouldn't be interested in their grapes since they clearly weren't organic, and asked why the grapes were advertised as such, their answer was basically, "Ok, thanks!"

In other words, they knowingly misrepresented their viticulture. They overstated. They lied.

The sad truth is that usually, when a winegrower or wine salesperson says that they are "practicing organic" in their vineyards - but doesn't back it up with certification - they are lying.

Technically a vineyard cannot be organic unless it is certified, because the term "organic" is legally protected and cannot be applied to agricultural practices or products without certification.

This protects us consumers from the willy-nilly use of "organic" as a marketing ruse by unscrupulous winegrowers. Without legal enforcement the term would become basically meaningless. This is a big problem with the terms "natural" and "sustainable."

Also, what is often overlooked is that "organic" isn't simply about eliminating conventional pesticides. You must also only fertilize with organic fertilizer. (Miracle Gro is not organic.) You can see in the graphic that this vineyard's fertilization schedule gives no indication that it is organic.

As an aside, I don't worry as much about conventional fertilizers as I do about pesticides, even though I think composts and other organic fertilizers are better solutions to soil health, especially long term. However, if you use conventional fertilizers, you definitely can't say you're "organic."

To their credit, they immediately provided me with the above info after my initial inquiry. But still.

"Organic But Not Certified"

On the one extreme, there are wineries who knowingly make false organic claims for the marketing advantage.

In the middle are those who farm "mostly" according to organic regulations, but sometimes use conventional chemicals "if they need to." Or perhaps they use only organically allowed pesticides but then use conventional fertilizers.

And then there are the tasting room attendants and sales people who may be clueless or careless with the term or who misunderstand what it means and conflate it with "sustainable" or just "carbon based" (as in chemistry).

But not everyone is lying. Organic certification takes three years, regular paperwork, and some small cost for certification fees each year. If you're a smaller winery in a non-prime region, being able to market your vineyard legally as "organic" may not be worth the hassle even if you actually farm your grapes that way.

You can, of course, choose to farm according to organic regulations, or even better, yet not get certified.

At our home in Los Angeles, Wendy and I have been gardening and tending grape vines and fruit trees according to organic regulations for 8 years. When we give away our excess produce or homemade wine, we tell people that it was "organically grown."

We certainly aren't certified, and technically can't call our homebrew "organic." But it's a lot easier to tell a neighbor, "This homemade wine is organic," rather than "The grapes for this wine were grown without any synthetic chemical inputs according to the same regulations used in organic farming."

Explaining the legal distinction between something that is actually organic, because it was certified, and something that was grown exactly the same way but without certification, can be a mouthful. Heck, I'm writing an entire article about it here. So at times saying you grew something "organically" is just a kind of shorthand, even if you know it's not technically correct.

It's one thing when you're talking about giving away homemade wine, however, and something very different when you're using this "shorthand" to sell grapes or wine from a commercial vineyard. I understand why it's done, and that it can be done with integrity. But (and I'm speaking here about what I'd condone not what is strictly legal) in wine commerce the term "organic" should only ever be applied to non-certified vineyards when two fully informed and understanding parties are communicating directly, and should be clarified as "not certified." The term "organic" should never be used publicly in print or video if certification is not involved.

Further, if you're going to claim that you "practice organic viticulture without certification," you should offer proof by presenting records of pesticide and fertilizer use for each vintage claimed to be farmed "organically."

How Do I Know If Organic Claims Are True?

In the absence of any evidence to support a claim of "organic but not certified" you should assume the claim is false.

If someone cares about the claims they are making of their grapes or wine, they should go out of their way to prove the truth of them.

Wineries know it's difficult to verify the truth of these claims. So if a winery doesn't offer an easy way to verify them, then they are likely relying on the law of inertia, or customer apathy, to prevent any deep dives into the truth of their claims.

I say this as someone who sources wine from both certified organic or biodynamic vineyards and some vineyards that do actually follow organic viticulture practices completely, yet choose not to be certified. If I'm looking for grapes and come across a vineyard that claims to be "practicing organic but not certified," here's what I do to verify whether or not they are actually following organic regulations:

  1. Look at their Pesticide Use Report - "PUR" (California)

  2. Every wine grape grower in California must report every pesticide they use in their vineyards throughout the year, each year. There are online records of pesticide use for every year dating back to 1974. You can read my article about getting a winegrower's PUR here.

  3. Ask direct questions of the winegrower

  4. Often the easiest way to quickly get to the truth of "organic" claims is to talk with the vineyard owner and ask them direct questions about what they fertilize with and what pesticides they use. Ask for a list of everything they use, and ask for their PUR. Ask them why they aren't certified. Ask them how they maintain vineyard health and prevent disease and fungus issues.

  5. Assess the winegrower's openness to provide information

  6. When asked, does the winegrower immediately offer clear, documented information? Do they express values that align with their claims? Can they give specific details about their vineyard's viticulture? Do they have a good explanation as to why they are not certified? Are they willing to provide lists, reports, and other documentation to show what they use in the vineyard?

  7. Visit the vineyard

  8. Arrange for a vineyard tour. Look for visual clues about what was used in the vineyard - things like empty pesticide or fertilizer containers, compost piles, or other signs of holistic approaches to viticulture. Things like un-plowed/un-tilled vineyard rows, sheep or chickens (used for winter cover crop control, as well as fertilizer), owl/raptor nesting boxes, and careful canopy management can be indications of values that align with organic viticulture practices. Ask all of the same questions again.

You Gotta Have Faith - Skeptically

Do all the pieces of information align? Does the winegrower seem like they are keeping anything from you? Ultimately you'll have to make a judgement call.

If a winegrower wants to be dishonest, they can. If they don't want to report that they used a conventional chemical, they can just omit it from their PUR. It can be difficult for the state regulating agencies to discover and penalize the omission. This is true even in certified organic vineyards.

So be skeptical. Verify any "organic but not certified" claims as best you can. Trust only after evaluating for yourself.

Fortunately, the stakes aren't often high enough for a winegrower to try to get away with full-blown deception. Sure it can at times be easier to sell your grapes if people think they were grown organically. And sometimes you can charge a bit more for them. But so far these advantages aren't extreme enough to warrant outright corruption.

If the market changes, we'll see.

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