United States Department of Agriculture 1400 Independence Avenue SW. Policy Memo 10-2

Agricultural Marketing Service Room 2646-South Building

National Organic Program Washington, DC 20250

NOP PM 10-2 Sulfur Dioxide in wine made with organic fruit Rev03 03 20 24 Authorized Distribution: Public 

Page 1 of 2

Policy Memorandum

To: Accredited Certifying Agents and State Organic Programs

From: Miles McEvoy, Deputy Administrator

Subject: Sulfur Dioxide in wine made with organic fruit

Date: Original Issue Date – September 20, 2010

Links and Contact Information Updated March 20, 2024

The Agricultural Marketing Service (AMS) maintains a Memorandum of Understanding (MOU)

with the Alcohol, Tobacco Tax and Trade Bureau (TTB). Under this MOU, the TTB receives,

reviews, and approves or rejects labeling applications for alcohol products bearing an organic

claim.

The TTB recently received a label application for a product that contained sulfur dioxide in a

wine which qualified for the "made with organic***" classification, but which was made with

fruit other than grapes, e.g., pears and blueberries. The TTB requested clarification from the

NOP on whether sulfur dioxide is allowed in a "made with organic (fruit other than grapes)"

wine.

The National Organic Program (NOP) examined its own record of decisions regarding wine 

labels and sought legal opinion on this issue. According to the USDA Office of General Counsel 

(OGC), Section 205.605(b) of the USDA organic regulations (7 CFR part 205) allows the use of 

sulfur dioxide in wines that are "made with organically grown grapes" (emphasis added). 

Because the regulations specify "grapes" in this annotation, the use of sulfur dioxide in other true 

fruit wines (i.e., those that are made with organic fruit other than grapes), and which are labeled, 

"made with organically grown (fruit other than grapes)", is prohibited. The NOP issued a memo 

to TTB on September 8, 2010, informing them of this clarification.

This policy clarification applies to wines classified as "true fruit wines" by the TTB. Please note

that some wines are made with organically grown grapes and contain other organic fruit added

for flavoring. These wines are not be affected by this policy. According to TTB, grape wines

that have other fruit added for flavoring are not true fruit wines. Thus, these wines can be

properly described with the claim "made with organically grown grapes," and contain added

sulfites as specified under section 205.605(b) of the NOP regulations.

If you have any questions regarding this memo, you may contact NOP.Guidance@usda.gov.
United States Department of Agriculture 1400 Independence Avenue SW. Policy Memo 10-2

Agricultural Marketing Service Room 2646-South Building

National Organic Program Washington, DC 20250

NOP PM 10-2 Sulfur Dioxide in wine made with organic fruit Rev03 03 20 24 Authorized Distribution: Public 

Page 2 of 2

References:

USDA Organic Regulations (7 CFR Part 205)

7 CFR 205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on 

processed products labeled as “organic” or “made with organic (specified ingredients or food 

group(s))”....

(b) Synthetics allowed... Sulfur dioxide—for use only in wine labeled “made with 

organic grapes,” Provided, That, total sulfite concentration does not exceed 100 ppm.