What's Actually in Your "American" Wine?

The label says one thing. The law says another.

The California Association of Winegrape Growers (CAWG) recently asked a pointed question on Substack: if "American" on a wine label doesn't mean American grapes, what exactly does it mean, and who benefits from that ambiguity?

It's a good question. The answer is complicated.

The piece was written in support of AB 1585, a California bill that would require wines labeled "American" to be made from 100% American-grown grapes. Right now, federal law only requires 75%. That means a bottle with "American" on the label can legally contain up to 25% foreign bulk wine, shipped in by the tanker load, with no disclosure to the consumer. The CAWG put it plainly: the value of "American" wine wasn't built in bladders of foreign bulk shipped across the world. It was grown out of American soil by family farmers, farmworkers, and wineries over generations.

Origin transparency at the national level is only one piece of the puzzle. What happens when you zoom in to states, to AVAs, to individual vineyards, gets even more interesting. If you're new to what an AVA actually is and why it matters, I broke that down in depth in this Foundations post. It's worth reading alongside this one.

Three States, Three Different Answers

The federal baseline from the TTB gives you a floor, not a ceiling. Federal rules require that if a wine label lists a county, state, or country as the wine's place of origin, at least 75% of the wine must be produced from grapes grown there. That number rises to at least 85% if the label lists a specific AVA. I covered the full breakdown of how those rules show up on a label here.

Some states decided that floor wasn't high enough.

Oregon built the most demanding framework in the country. If a label indicates "Oregon," an Oregon county, or an AVA, 100% of the grapes must be from Oregon, and 95% have to come from the specified appellation. Oregon also raised the bar on varietal labeling. Where other states only require 75% of the grapes used to make a wine to be of the declared variety, Oregon requires 90% or more. That means a Pinot Noir from Oregon is actually mostly Pinot Noir in a way the law doesn't guarantee elsewhere. Oregon even signed the Joint Declaration to Protect Wine Place and Origin, a global coalition of 19 wine regions committed to origin integrity. They are serious about this.

Washington takes a different line. Washington State largely follows TTB federal guidelines, requiring 85% for AVA claims. Better than the national floor, but not Oregon.

Texas is the most interesting case, and the most relevant to me personally. The state passed HB 1957 in 2021, creating what got nicknamed the "Grape Compromise." Under the new law, labels listing an AVA must include 85% grapes from within the stated AVA, with the remaining 15% from within Texas. The key word is within Texas. Any wine labeled with a Texas county, AVA, or vineyard must be made from 100% Texas fruit. The loophole: a wine labeled simply "Texas" with no AVA, no county, still only needs 75% Texas grapes, in line with federal minimums. It's a tiered system that rewards specificity and punishes vagueness. I covered the Texas Hill Country AVA in detail if you want the full picture.

The Producer/Vintner Problem

Here's where it gets thorny, and where Jon Bonne's 2013 The New California Wine still resonates more than a decade later. Bonne documented a California wine culture where the commercial and the artisanal were constantly in tension. The producer growing the grapes and the vintner making the wine don't always share the same interests, and the label doesn't always tell you which one is in charge.

That tension is still very much alive. And it shows up in a grape most consumers have never heard of: Alicante Bouschet.

Alicante Bouschet is a teinturier, one of the rare grapes where the flesh, not just the skin, is deeply pigmented. It bleeds purple. In a blending context, that's a cheat code: add a small percentage to a thin, pale red, and suddenly you have something that looks powerful and concentrated. The color says Cabernet. The grapes might say otherwise.

Here's the thing, though. When a California winemaker reaches for Alicante Bouschet, they're almost certainly reaching for California fruit. The variety has been planted heavily in the Central Valley since Prohibition, when home winemakers prized it precisely because its thick skin and dark juice survived the cross-country rail trip intact. Today it's an established part of the California vineyard landscape. The flexibility to blend it in is a legitimate tool, and the grapes are domestic. That part of the story is fair.

The problem isn't Alicante Bouschet. The problem is what happens when a winery needs to close a gap in volume or cost, and the solution isn't a domestic blending grape but a flexitank. Between 2003 and 2022, bulk imports jumped from zero to 400,000 tons a year. According to the Lodi Winegrape Commission, citing Gomberg Fredrickson trade data, nearly 68 million gallons of foreign bulk wine was imported by California wineries in 2022, with sourcing coming from Chile, Australia, Italy, and New Zealand. Under current federal rules, up to 25% of that blend can come from anywhere on earth and the label can still say "American." The consumer sees a domestic brand and assumes domestic grapes. The math doesn't require it.

This isn't illegal. But it's the kind of practice the CAWG article is circling when it notes that decisions that prioritize short-term savings come at the expense of the long-term health of the very industry we are all trying to save.

The issue isn't that blending exists. Blending is fundamental to winemaking. The issue is that the current system creates a gap between what the consumer sees and what's actually in the bottle, and some producers have learned to live very comfortably in that gap.

What Do Consumers Actually Want?

The SVB 2026 State of the Wine Industry Report drops some uncomfortable context here. The older, wine-focused cohort is aging out, and younger adults aren't replacing them at the same rate. Millennial and Gen Z drinkers are spread across more categories and drinking less overall. The report is direct about what that means for producers: the wineries holding ground are not waiting for a rebound. They are focusing on customer alignment and brand clarity, treating direct-to-consumer as a loyalty engine, not just a sales channel. Loyalty requires trust. Trust requires honesty about what's in the bottle. A brand that can't answer the question of where these grapes actually came from is not building the kind of relationship that earns a second sale, and SVB is clear that the second sale matters more than the first.

The Movement for 100%

AB 1585 is further along than most people realize. Co-sponsored by CAWG (cawg.org) and Family Winemakers of California (familywinemakers.org), the bill had its first committee hearing in Sacramento on April 22, with nearly 300 letters of support submitted, backed by wineries, growers, and industry partners across the state, along with 19 regional associations. If passed, it would apply to wines bottled on or after July 1, 2027, giving producers time to adjust sourcing before the rule takes effect.

The opposition is real. The Wine Institute, representing many of the largest producers, voted to oppose the bill on grounds of flexibility, regulatory cost, and market timing. The CAWG rebuttal is worth reading in full at the link above. The short version: the "flexibility" argument protects imports at the expense of domestic growers, and the "wrong moment" framing has been used to block this kind of reform since at least 2009. The "right moment" never seems to arrive, which suggests "now is not the time" is what gets said when the real answer is too uncomfortable to give directly.

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The Bigger Picture

AB 1585 would close one gap. Texas's Grape Compromise closed another. Oregon closed most of them years ago. But even in Oregon, you can make a wine from 90% Pinot Noir, never disclose the other 10%, and call it Pinot Noir on the label.

The CAWG is right that no other major wine-producing country allows foreign wine to be blended into their national brand. France doesn't. Italy doesn't. Argentina doesn't. The United States is the outlier.

But there's a version of this conversation that goes further, past origin, past state lines, past the neat AVA boundary, and asks what a wine actually is from grape to glass. Some producers are choosing to answer that question voluntarily, through QR codes, full ingredient disclosure, and more specific back labels. Others are counting on the fact that most consumers won't ask.

The label on the bottle is a promise. Whether it's kept is a different matter entirely.

Fun Facts

The TTB's federal baseline requires only 75% domestic grapes for a state-labeled wine, unless a state passes its own stricter law.
Alicante Bouschet is one of a small handful of teinturier grapes, varieties where both the skin and the flesh produce pigment. Most red wine grapes have clear flesh; color comes entirely from skin contact during maceration.
The U.S. wine industry sold approximately 329 million cases in 2025, down from 335.9 million in 2024 and well below the 410 million cases sold in 2019. (SVB 2026 State of the Wine Industry Report)