At the beginning of the millennium, tossing a word like terroir into a conversation about wine would’ve been considered snobbish and elitist. The fact that terroir doesn’t have a direct translation only intensifies its pomposity. This French word is meant to impart an idea. The term insists that soil and microclimates deeply affect the taste of food and drink, and this makes the place in which something is grown or created intrinsically related to and inseparable from its flavor. But that’s a mouthful. Instead of launching into such a fumbling definition, Americans have at long last adopted the French word in English use. In today’s foodie parlance, terroir means “taste of place,” and the term has the power to shape both historical standards and future innovations for winemaking.
It should come as no surprise that a people with a specific word to describe the concept for where a taste originates also developed an entire legal code dedicated to protecting individual terroirs throughout their small but diverse country. With this goal in mind, the French formed the Institut National de l’Origine et de la Qualité (INAO) in 1935 to support a series of legally defined geographical indications (GIs) with certifications known as Appellation d’Origine Contrôlées (AOCs). The purpose of these protections is to ensure that a wine’s name has the ability to convey not just where, but how, it’s made. Further, that name tells a consumer exactly why it has a unique taste.
The INAO also dictates and protects where and how specialized foods are made, including cheese, such as Roquefort, which was notably the first French product in which authenticity was tethered to terroir in 1411; hot dried peppers, such as Piment d’Espelette; and even a specific chestnut from Ardèche. Still, the vast majority of these protections are bestowed to the formidable French wine industry. There are more than 300 viticulture AOCs in France, the first of which was argued for — and given to — the vintners at Châteauneuf-du-Pape in the Cotes du Rhone (which is its own AOC) in 1937. Often the designations are named for regions, but they can get more nuanced than that. Take, for example, La Romanée, the smallest AOC in France, with only a 2.1-acre plot of grapes. This vineyard in Burgundy produces one of the world’s most sought-after pinot noirs.
The minutiae for the AOC designation can be strict and comprehensive, from growing and planting density regulations to aging processes. Yet, taste can be surprisingly nuanced even among fellow producers of the same designation. The products are monitored and tasted by local experts often with close ties to the producers; an imperfect control for a rigorous set of standards.
The regulations are so comprehensive, in fact, that AOCs have been blamed by a new generation of producers as stifling innovation and inhibiting the agility needed for new viticulture practices to combat stagnant markets and the effects of climate change on the industry. Some cognac growers experiment with aging in casks different from the traditional (and required) French Limousin oak. Other growers under the same AOC experiment with new grape varietals that would be more amenable to hotter climate conditions. The reality is that current regulations protect targeted microclimates that are changing, or may no longer exist. Innovation is often met with controversy, resistance, appeals to tradition, and, ultimately, discipline under current French law.
Despite its flaws, the primacy, dedication, and resulting protection that the French AOCs give terroir has been inspirational to many countries. The European Union has expanded the idea by designating Appellation d’Origine Protégées (AOPs) across its 28 members. Italy followed with its own Denominazione di Origine Controllata e Garantita; Germany created Qualitätswein bestimmter Anbaugebiete; and Portugal defers to the Denominação de Origem Controlada. South Africa has Wine of Origin, while Canada has the Vintners Quality Alliance. Conspicuously missing from this list is the United States.
Trademark vs. Terroir
From a French point of view, the U.S. seems to be unconcerned with — or perhaps ignorant of — terroir and the European codes and laws that profess to uphold the integrity and importance of place. Instead, American makers adhere to trademark law.
Wine production in the U.S. has long felt like the Wild West in comparison to the rigors and rules of orderly French production. American varietals are fêted for innovation and taste, with a new and well-received pivot toward organic and natural markets, alongside a redefinition and expansion of taste profiles. But for the better part of the 20th century, American wine mimicked many of its European brethren. To that end, French flavor profiles were shamelessly copied, European vines were grown on U.S. soil, “châteaus” sprung up in Northern California, and names were borrowed and rebranded.
Specifically, names of individual GIs were liberally assigned to areas within U.S. wine growing regions. For example, the Korbel family started marketing its sparkling white wine, grown in California, as “champagne” as early as the 1880s. Other names of place were taken too; a sauterne in the U.S. isn’t the Sauternes of Bordeaux, but it’s certainly meant to evoke the latter. The contention of the French is that it’s also meant to trick the consumer into assuming the wines are parallel, or worse, equal. To them, the idea of calling a wine that happens to be sparkling and white “champagne” just because of those two minor qualities is incroyable.
The guiding principle that holds trademark over terroir is an extension of the pillars that American industry is built upon: innovation over tradition, or the insistence that anything can be made better, and that as little as possible should stand in the way of this pursuit. To some extent, this does make growing wine in America a more independent undertaking. American vintners have the freedom to explore new varietals, as well as planting, growing, and harvesting practices that are dictated solely by the grower and the grower’s market. Their French counterparts can’t achieve such freedom without having to remove all pertinent names from their bottles, reducing the wine to the vague vin du pays, or worse, vin du table. Detractors from total viticultural freedom would remind consumers of the less savory practices common at some vineyards, such as putting wood chips in aging barrels to fake the taste of oak in a flavor profile. Without regulation, truly anything is possible, but that can reach both ends of the spectrum when it comes to what’s in the best interest of the consumer and the trade.
The French wine industry has been pleading with the American industry for the last 100 years to change its laws in order to protect French wine globally. Trade wars ensued, but to no result. Instead, American vintners continued to use French geographical names with impunity and to such a prodigious degree that the names have been upheld in U.S. courts as having become generic. In 1978, the Bureau of Alcohol, Tobacco, Firearms, and Explosives, which regulates the wine industry, formalized an appellation program for U.S. vintners. It divided appellations into three categories: generic, semi-generic, and nongeneric. Essentially, if a wine is from California, Oregon, Vermont, etc., it needs to be labeled as such. Sparkling white wine from Napa Valley can be labeled “Champagne from California.” Trademarks prevailed; the French were furious.
Advancing Trade Agreements
If the U.S. and French wine markets existed in a vacuum, none of this would matter, but, of course, they don’t. Competition became prickly between the two nations, specifically with France attempting to bar imports of American wines into their country. In 1993, the Agreement of Trade-Related Aspects of Intellectual Property Rights (TRIPS) attempted to end the antagonistic trade war on wine and recognized wine appellations as intellectual property rights. Essentially, TRIPS was intended to obviate the trend of GIs devolving into generic or semi-generic terms. The agreement prohibited the false application of these GIs, or falsely implicating a source of the wine. But, like any international agreement, there were those powerful enough to get an exception to the rule, and an important asterisk was added onto TRIPS: Any registered trademarks before the effective date of the agreement would be grandfathered into it. Korbel’s California Champagne held.
A 2006 agreement on trade in wine further worked to mend the rift between the two markets, preventing both the French and American markets from blocking wine imports based solely on the other’s viticultural practices. Here, the U.S. also pledged to seek protection for 17 semi-generic names, including burgundy, chianti, port, sauterne, sherry, and champagne. By some estimates, even today, more than 50 percent of sparkling white American wine is sold with the word “champagne” on the bottle. The deadlock, and argument, continues for American vintners and their French counterparts.
In 2007, the European Union bestowed the first American GI to Napa Valley. Wines grown in Napa now mean something to the American palate and the world market that was indescribable 20 years before. It’s possible, as America’s young food and wine industry and culture develop, so too will the need to name its distinctive terroirs. Like the history of the French and their famous wine, the solemnity of American terroirs will perhaps increase with time, and allow for a more nuanced taste of place.
Kate MacLean shares a farm in the green and chilly hills of central Vermont with her children and husband, extended family, and 100 furred and feathered beasts. Follow her on Instagram @LongestAcresFarm.