The vinegar side

Naming a vinegar, and a 1924 Supreme Court case

Updated October 2026

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The definitions The case Which is why the dried-apple rule exists Blends are named in order of predominance Where this catches small makers References

The definitions are specific about what each vinegar is made from, and the reasoning behind them is a hundred-year-old case about a name that was literally true and still misleading.

The definitions

Vinegar, cider vinegar, apple vinegar: the product of the alcoholic and subsequent acetous fermentations of the juice of apples.
Wine vinegar, grape vinegar: the same, from the juice of grapes.
Malt vinegar: from an infusion of barley malt or cereals whose starch has been converted by malt, without distillation.
Spirit, distilled or grain vinegar: from the acetous fermentation of dilute distilled alcohol.

The case

In U.S. v. 95 Barrels, More or Less, Alleged Apple Cider Vinegar in 1924, the Supreme Court held that vinegar made from dried apples was not the same as that which would have been produced from the apples without dehydration, and that the name apple cider vinegar did not represent the article to be what it really was. The product was vinegar and it was made from apples, and the name was still wrong.

Which is why the dried-apple rule exists

Vinegar made from dried apples, apple cores or apple peels is to be labeled as vinegar made from, with the blank filled in with the apple product used. The rule is narrow and the principle behind it is not: a name that is defensible word by word can still misrepresent the thing in the bottle.

Blends are named in order of predominance

A vinegar made from a mixture should be labeled as a blend of the products with the names in order of predominance. That is the same structure the syrup rules use, and the same instinct it is guarding against.

Where this catches small makers

Usually in the enthusiasm of describing a product. A vinegar started from a commercial wine, or from scraps and peelings, or from a cider somebody else made, is a fine product and it is not always the thing its obvious name would suggest. The definitions are specific about the starting material for exactly that reason, and reading them takes five minutes against the cost of a print run.

The useful test before printing is to ask what a buyer would assume the vinegar was made from on reading the name, and whether that assumption is correct.

References

United States Food and Drug Administration. Compliance Policy Guide Sec. 525.825, Vinegar, Definitions: “No standards of identity for vinegar have been established under the Federal Food, Drug, and Cosmetic Act,” and each listed variety “should contain 4 grams of acetic acid per 100 mL.” fda.gov

Written from federal regulation, voluntary USDA grade standards, FDA labeling policy and published extension guidance, not from a laboratory. The infused-oil pages describe a real botulism hazard and are a starting point for a conversation with your state department of agriculture and a process authority, not a determination that any method you use is safe.