1. Certificates of Analysis
2017 International Wine Technical Summit
Certificates of Analysis
Gallo produces amazing wines in every category, to suit every taste.  Gallo also imports wines from nine wine growing countries in the world.  Gallo’s wine portfolio totals over 60 unique brands:
Barefoot is the number 1 wine in the US and has introduced many new wine drinkers to the wine category.
In 2011 alone we updated the Bella Sera Label and updated the Redwood Creek Label. Last year we also introduced The Naked Grape from California and Bodega Elena from Argentina.
June 20, 2017
Paul Huckaba, Bronco Wine Company

2. Certificates of Analysis
Overview:
Background
FIVS Paper on Certificates of Analysis
3. is Wine an inherently safe product?
4. Are Certificates of analysis necessary?
5. What about Laboratory Data?
6. Summary, and A proposal
Gallo produces amazing wines in every category, to suit every taste.  Gallo also imports wines from nine wine growing countries in the world.  Gallo’s wine portfolio totals over 60 unique brands:
Barefoot is the number 1 wine in the US and has introduced many new wine drinkers to the wine category.
In 2011 alone we updated the Bella Sera Label and updated the Redwood Creek Label. Last year we also introduced The Naked Grape from California and Bodega Elena from Argentina.

3. Tbilisi Statement, Principle #01 - AVOID UNNECESSARY ANALYSIS
Certificates of Analysis
“The Tbilisi Statement”
“The ‘Statement on Analytical Methodology and Regulatory Limits’ was adopted to remove unnecessary obstacles to international wine exports. The principles, finalized at the trade group's annual meeting in Tbilisi, Georgia on Aug , 2014, were proposed to address a continuing pattern of wine trade barriers. Many countries establish unnecessary rules which delay and add to winery costs, resulting in restricted market access and trade.” (
Gallo produces amazing wines in every category, to suit every taste.  Gallo also imports wines from nine wine growing countries in the world.  Gallo’s wine portfolio totals over 60 unique brands:
Barefoot is the number 1 wine in the US and has introduced many new wine drinkers to the wine category.
In 2011 alone we updated the Bella Sera Label and updated the Redwood Creek Label. Last year we also introduced The Naked Grape from California and Bodega Elena from Argentina.
Tbilisi Statement, Principle #01 - AVOID UNNECESSARY ANALYSIS
“GOVERNMENTS SHOULD ESTABLISH REGULATORY LIMITS THAT ARE BASED ON RISK, THEREBY AVOIDING UNNECESSARY ANALYSIS.”

4. Certificates of Analysis
In the APEC region, “…the costs of unnecessary testing and certification in the region (were) estimated at 1 billion USD per annum.”
Gallo produces amazing wines in every category, to suit every taste.  Gallo also imports wines from nine wine growing countries in the world.  Gallo’s wine portfolio totals over 60 unique brands:
Barefoot is the number 1 wine in the US and has introduced many new wine drinkers to the wine category.
In 2011 alone we updated the Bella Sera Label and updated the Redwood Creek Label. Last year we also introduced The Naked Grape from California and Bodega Elena from Argentina.
$1,000,000,000 USD
$?,???,???,??? USD

5. Certificates of Analysis
FIVS paper on Certificates of analysis
IWTS Lab Quality group
FIVS Scientific and Technical Committee
Gallo produces amazing wines in every category, to suit every taste.  Gallo also imports wines from nine wine growing countries in the world.  Gallo’s wine portfolio totals over 60 unique brands:
Barefoot is the number 1 wine in the US and has introduced many new wine drinkers to the wine category.
In 2011 alone we updated the Bella Sera Label and updated the Redwood Creek Label. Last year we also introduced The Naked Grape from California and Bodega Elena from Argentina.

6. Certificates of Analysis
Is wine an inherently safe product?
A collection of “requested” tests for COAs
Appearance
Hybrids
Stability at -5°C
Bacteria, cultured
Iron
Sucrose
Calories
Lead
Sugar Free Extract
Citric Acid
Limpidity
Titratable Acidity (TA)
Color (sensory evaluation)
Methanol
Total Alcoholic Strength
Copper
Molecular Sulphur Dioxide (SO2)
Total Dry Extract
Density pH
Total Sugar (Reducing Sugar - Inverted)
Ethanol
Reducing Sugar
Total Sugar
Free Sulphur Dioxide (SO2)
Remaining Extract
Total Sulphur Dioxide (SO2)
Fungus, cultured
Sorbic Acid
Volatile Acidity (VA)
Gas Pressure at 20°C
Specific Gravity
Volume per Bottle
Glucose + Fructose (sugars)
Stability at 55°C
Yeast, cultured
Gallo produces amazing wines in every category, to suit every taste.  Gallo also imports wines from nine wine growing countries in the world.  Gallo’s wine portfolio totals over 60 unique brands:
Barefoot is the number 1 wine in the US and has introduced many new wine drinkers to the wine category.
In 2011 alone we updated the Bella Sera Label and updated the Redwood Creek Label. Last year we also introduced The Naked Grape from California and Bodega Elena from Argentina.

7. Certificates of Analysis
Is wine an inherently safe product?
We can group tests into 6 main categories
Health and Safety – (e.g., Total SO2)
Wine Quality and Legality – (e.g., Ethanol, Methanol, VA)
Additive Levels – (e.g., Sorbic Acid, Citric Acid)
Microbiological – (e.g., Yeast, Bacteria, Mold, “Fungus”)
Physical Characteristics – (e.g., Stability, Color, Limpidity)
Typical Wine Parameters – (e.g., pH, Sugars)
Gallo produces amazing wines in every category, to suit every taste.  Gallo also imports wines from nine wine growing countries in the world.  Gallo’s wine portfolio totals over 60 unique brands:
Barefoot is the number 1 wine in the US and has introduced many new wine drinkers to the wine category.
In 2011 alone we updated the Bella Sera Label and updated the Redwood Creek Label. Last year we also introduced The Naked Grape from California and Bodega Elena from Argentina.

8. Certificates of Analysis
Is wine an inherently safe product?
“Health and Safety”
Sulfur Dioxide (SO2)
Methanol
Heavy Metals
Gallo produces amazing wines in every category, to suit every taste.  Gallo also imports wines from nine wine growing countries in the world.  Gallo’s wine portfolio totals over 60 unique brands:
Barefoot is the number 1 wine in the US and has introduced many new wine drinkers to the wine category.
In 2011 alone we updated the Bella Sera Label and updated the Redwood Creek Label. Last year we also introduced The Naked Grape from California and Bodega Elena from Argentina.
Concentrations are too low for concern

9. Certificates of Analysis
Is wine an inherently safe product?
“Wine Quality and Legality”
Ethanol
Gas Pressure
Methanol
Volatile acidity
Gallo produces amazing wines in every category, to suit every taste.  Gallo also imports wines from nine wine growing countries in the world.  Gallo’s wine portfolio totals over 60 unique brands:
Barefoot is the number 1 wine in the US and has introduced many new wine drinkers to the wine category.
In 2011 alone we updated the Bella Sera Label and updated the Redwood Creek Label. Last year we also introduced The Naked Grape from California and Bodega Elena from Argentina.
Quality and legality don’t affect safety

10. Certificates of Analysis
Is wine an inherently safe product?
“Additive Levels”
Mostly Grape-Derived
Difficult to determine added amount
Good Manufacturing Practice (GMP) usage
Minimal usage
No risk, Based on jecfa evaluations
Gallo produces amazing wines in every category, to suit every taste.  Gallo also imports wines from nine wine growing countries in the world.  Gallo’s wine portfolio totals over 60 unique brands:
Barefoot is the number 1 wine in the US and has introduced many new wine drinkers to the wine category.
In 2011 alone we updated the Bella Sera Label and updated the Redwood Creek Label. Last year we also introduced The Naked Grape from California and Bodega Elena from Argentina.
Concentrations are too low for concern

11. Certificates of Analysis
Is wine an inherently safe product?
“Microbiological”
Yeast/fungus, Bacteria (Quality only)
Pathogens (E. Coli, Salmonella)
“Microbiologically, wine is a low food safety risk consumer product” (
Gallo produces amazing wines in every category, to suit every taste.  Gallo also imports wines from nine wine growing countries in the world.  Gallo’s wine portfolio totals over 60 unique brands:
Barefoot is the number 1 wine in the US and has introduced many new wine drinkers to the wine category.
In 2011 alone we updated the Bella Sera Label and updated the Redwood Creek Label. Last year we also introduced The Naked Grape from California and Bodega Elena from Argentina.
Pathogens don’t survive in wine

12. Certificates of Analysis
Is wine an inherently safe product?
“Physical Characteristics”
Color, limpidity (clarity), Stability
Subjective descriptors
Can vary based on tradition, culture, fashion, or style.
Gallo produces amazing wines in every category, to suit every taste.  Gallo also imports wines from nine wine growing countries in the world.  Gallo’s wine portfolio totals over 60 unique brands:
Barefoot is the number 1 wine in the US and has introduced many new wine drinkers to the wine category.
In 2011 alone we updated the Bella Sera Label and updated the Redwood Creek Label. Last year we also introduced The Naked Grape from California and Bodega Elena from Argentina.
Characteristics of wine don’t affect safety

13. Certificates of Analysis
Is wine an inherently safe product?
“Typical Wine Parameters”
pH, Acidity, sugars, density, etc.
Grape-Based, so a narrow range of values
Additions – more of the same?
Gallo produces amazing wines in every category, to suit every taste.  Gallo also imports wines from nine wine growing countries in the world.  Gallo’s wine portfolio totals over 60 unique brands:
Barefoot is the number 1 wine in the US and has introduced many new wine drinkers to the wine category.
In 2011 alone we updated the Bella Sera Label and updated the Redwood Creek Label. Last year we also introduced The Naked Grape from California and Bodega Elena from Argentina.
Safe in the grapE? Safe in the wine!

14. Certificates of Analysis
Are certificates of analysis necessary?
Certificate of analysis tests Are either:
Not related to health and safety
Declared on the bottle
Unlikely to reach harmful levels in wines made using Good Enological Practice
So…are they necessary?
Gallo produces amazing wines in every category, to suit every taste.  Gallo also imports wines from nine wine growing countries in the world.  Gallo’s wine portfolio totals over 60 unique brands:
Barefoot is the number 1 wine in the US and has introduced many new wine drinkers to the wine category.
In 2011 alone we updated the Bella Sera Label and updated the Redwood Creek Label. Last year we also introduced The Naked Grape from California and Bodega Elena from Argentina.

15. Certificates of Analysis
Are certificates of analysis necessary?
What if your country decides they are?
Have Clearly defined requirements
Have Acceptable data quality
Have Results Within tolerance,
plus uncertainty
Next up: laboratory data
Gallo produces amazing wines in every category, to suit every taste.  Gallo also imports wines from nine wine growing countries in the world.  Gallo’s wine portfolio totals over 60 unique brands:
Barefoot is the number 1 wine in the US and has introduced many new wine drinkers to the wine category.
In 2011 alone we updated the Bella Sera Label and updated the Redwood Creek Label. Last year we also introduced The Naked Grape from California and Bodega Elena from Argentina.

16. Certificates of Analysis
What about laboratory data?
1. Clearly defined requirements
--What exactly is being regulated?
For example, “Sugars”
the quantity of compounds capable of reducing an alkaline cupric solution
the combined quantities of saccharides and disaccharides
the amount of fermentable sugars present
the amount of glucose, fructose and sucrose present
(Sacarose/sacarosa/saccharose?)
Gallo produces amazing wines in every category, to suit every taste.  Gallo also imports wines from nine wine growing countries in the world.  Gallo’s wine portfolio totals over 60 unique brands:
Barefoot is the number 1 wine in the US and has introduced many new wine drinkers to the wine category.
In 2011 alone we updated the Bella Sera Label and updated the Redwood Creek Label. Last year we also introduced The Naked Grape from California and Bodega Elena from Argentina.

17. Certificates of Analysis
What about laboratory data?
2. Acceptable data quality?
Laboratory data quality programs
Certification/accreditation
ISO – A single, International standard
Enforcement labs
Producer or third-party Labs
Gallo produces amazing wines in every category, to suit every taste.  Gallo also imports wines from nine wine growing countries in the world.  Gallo’s wine portfolio totals over 60 unique brands:
Barefoot is the number 1 wine in the US and has introduced many new wine drinkers to the wine category.
In 2011 alone we updated the Bella Sera Label and updated the Redwood Creek Label. Last year we also introduced The Naked Grape from California and Bodega Elena from Argentina.
Both adhere to the same quality standard—ISO 17025, and the data should be widely accepted.

18. Is this the “Right Answer”?
Certificates of Analysis
What about laboratory data?
3. Within tolerance, plus uncertainty
Is this the “Right Answer”?
Small variations in
temperature
+ Analyst technique
+ Analyte Stability
+ Lots of other little things
Uncertainty
Gallo produces amazing wines in every category, to suit every taste.  Gallo also imports wines from nine wine growing countries in the world.  Gallo’s wine portfolio totals over 60 unique brands:
Barefoot is the number 1 wine in the US and has introduced many new wine drinkers to the wine category.
In 2011 alone we updated the Bella Sera Label and updated the Redwood Creek Label. Last year we also introduced The Naked Grape from California and Bodega Elena from Argentina.

19. Certificates of Analysis
What is Uncertainty?
Uncertainty of Measure – Codex Alimentarius’ Estimates
“it would be reasonable to anticipate that the (expanded) uncertainties reported by laboratories would be approximately the following”:1
Nominal
Concentration
Typical Expanded
Uncertainty
Expected Range of Results*
100 g/100g 4%
96 to 104 g/100g
10 g/100g 5%
9.5 to 10.5 g/100g
1 g/100g 8%
0.92 to 1.08 g/100g
1 g/kg
11%
0.89 to 1.11 g/kg
100 mg/kg
16%
84 to 116 mg/kg
10 mg/kg
22%
7.8 to 12.2 mg/kg
1 mg/kg
32%
0.68 to 1.32 mg/kg
< 100 μg/kg
44%
0.56 x concentration to 1.44 x concentration in ug/kg
Gallo produces amazing wines in every category, to suit every taste.  Gallo also imports wines from nine wine growing countries in the world.  Gallo’s wine portfolio totals over 60 unique brands:
Barefoot is the number 1 wine in the US and has introduced many new wine drinkers to the wine category.
In 2011 alone we updated the Bella Sera Label and updated the Redwood Creek Label. Last year we also introduced The Naked Grape from California and Bodega Elena from Argentina.
* this effectively means that values falling within these ranges may be regarded as being of the same analytical population.
1 Codex Alimentarius Commission (2011). Report of the Thirty Second Session of the Codex Committee On Methods Of Analysis And Sampling, Budapest.

20. Certificates of Analysis
What is Uncertainty?
Uncertainty of Measure – Codex Alimentarius’ application
“…where the test result is compared against the specification consisting of a maximum level. It illustrates how the concept of measurement uncertainty could be taken into account when interpreting analytical results on a tested sample. This diagram demonstrates the importance of defining clear guidelines to allow unambiguous and objective interpretation of analytical results with respect to their measurement uncertainties.” 1
Situation i
The analytical result minus the expanded measurement uncertainty exceeds the maximum level. The result indicates that the measured analyte in the test sample is above the specification.
Situation ii
The analytical result exceeds the maximum level by less than the expanded measurement uncertainty.
Situation iii
The analytical result is less than the maximum level by less than the expanded measurement uncertainty.
Situation iv
The analytical result is less than the maximum level by more than the expanded measurement uncertainty.
Gallo produces amazing wines in every category, to suit every taste.  Gallo also imports wines from nine wine growing countries in the world.  Gallo’s wine portfolio totals over 60 unique brands:
Barefoot is the number 1 wine in the US and has introduced many new wine drinkers to the wine category.
In 2011 alone we updated the Bella Sera Label and updated the Redwood Creek Label. Last year we also introduced The Naked Grape from California and Bodega Elena from Argentina.
Codex Alimentarius Commission (2011). Report of the Thirty Second Session of the Codex Committee On Methods Of Analysis And Sampling, Budapest.

21. Certificates of Analysis
Summary
Wine is inherently safe
COAs may not be necessary
When COAs are required:
Define the analyte well
Ensure quality results
Consider uncertainty
Gallo produces amazing wines in every category, to suit every taste.  Gallo also imports wines from nine wine growing countries in the world.  Gallo’s wine portfolio totals over 60 unique brands:
Barefoot is the number 1 wine in the US and has introduced many new wine drinkers to the wine category.
In 2011 alone we updated the Bella Sera Label and updated the Redwood Creek Label. Last year we also introduced The Naked Grape from California and Bodega Elena from Argentina.

22. Certificates of Analysis
A proposal
Could we follow the lead of the Apec Wine Regulatory Forum?
Current project:
To identify the current requirements for Certificates of Analysis among APEC economies
To consider the precise purpose these serve and whether they are essential
To contemplate a simplification by the elimination of Certificates of Analysis altogether or some progress towards harmonization for those economies where that may not be possible
“To increase wine production, to expand trade, and to create jobs in the region, we commit to eliminating unnecessary export certification for wine by 2018 and instruct officials to advance this work.” 2014 Joint Ministerial Statement
Gallo produces amazing wines in every category, to suit every taste.  Gallo also imports wines from nine wine growing countries in the world.  Gallo’s wine portfolio totals over 60 unique brands:
Barefoot is the number 1 wine in the US and has introduced many new wine drinkers to the wine category.
In 2011 alone we updated the Bella Sera Label and updated the Redwood Creek Label. Last year we also introduced The Naked Grape from California and Bodega Elena from Argentina.

23. Certificates of Analysis
Group Discussion:
Which authority in your country mandates the tests required on your certificates of analysis?
Are the certificates of analysis prescribed by law?
What is the process for requesting changes to the tests required?
Gallo produces amazing wines in every category, to suit every taste.  Gallo also imports wines from nine wine growing countries in the world.  Gallo’s wine portfolio totals over 60 unique brands:
Barefoot is the number 1 wine in the US and has introduced many new wine drinkers to the wine category.
In 2011 alone we updated the Bella Sera Label and updated the Redwood Creek Label. Last year we also introduced The Naked Grape from California and Bodega Elena from Argentina.

24. Gallo produces amazing wines in every category, to suit every taste
Gallo produces amazing wines in every category, to suit every taste.  Gallo also imports wines from nine wine growing countries in the world.  Gallo’s wine portfolio totals over 60 unique brands:
Barefoot is the number 1 wine in the US and has introduced many new wine drinkers to the wine category.
In 2011 alone we updated the Bella Sera Label and updated the Redwood Creek Label. Last year we also introduced The Naked Grape from California and Bodega Elena from Argentina.