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Wine Labels

  • Designing a Wine Label
  • Applying for a Wine COLA
  • Pre-COLA Evaluations for Wine
  • Wine Sulfite Analysis

Each wine container must be labeled with a government-approved label before it can be sold. The TTB is the government agency responsible for reviewing and approving alcohol beverage labels including wine labels. Generally, you must obtain a Certificate of Label Approval (“COLA”) for every label you intend to take to market. You can usually file a COLA application is soon as you receive a winery permit. You must submit a sample label with that application. In some cases, you must submit your product formula for TTB evaluation before filing a COLA application.

The following list is not comprehensive, but includes some of the most common wine label requirements. Depending on the type of spirits, location of bottling, and other factors, the required label information may differ from what’s included below.

To start, containers holding wine must have at least one label called the “brand label.” No other labels are required, but additional labels are permitted. As discussed below, certain information must be displayed on the brand label.

The brand label must include the brand name used to identify and market your wine. A brand name may not, either standing alone, or in association with other printed or graphic matter, mislead the consumer about the age, origin, identity or other characteristics of the product.

Examples: Barefoot; Ste. Chappelle

The varietal designation is the name of the dominant grape used in the wine. In most cases, the wine may only be designated using a grape varietal if 75% of the wine is derived from that variety of grape. When a varietal designation is used on a label, it must be accompanied by an appellation of origin (see below on appellations of origin). Wine labels are not required to have a varietal designation.

Examples: Merlot; Cabernet Sauvignon; Pinot Noir

Where appropriate, other designations may be used to identify the type of wine. Examples: Table Wine; Dessert Wine; Red Wine

The appellation of origin is the place where most of the grapes used in the wine were grown. It can be the United States, a state, up to three states which are all contiguous, a county, up to three counties in the same state, or a viticultural area. A U.S., county, state, or multi-state/multi-county appellation of origin can only be used if at least 75% of the wine is derived from grapes grown in the indicated area. When an appellation of origin is required, it must appear on the same label and in the same view as the varietal designation.

Examples: California; Walla Walla County

A viticultural area is a designated grape-growing region in the U.S. Its boundaries are defined by the TTB at the request of wineries and other petitioners. A viticultural area appellation on a wine label indicates that 85% or more of the wine was produced from grapes grown in the named area.

Examples: Napa Valley; Snake River Valley

All wine must be labeled with a health statement that is separated from other information on the bottle either through the use of space or on a separate label. The health statement may be on the brand label, back label, or on a separate front, side, or back label. The statement must state as follows: “GOVERNMENT WARNING: (1) According to the surgeon general, women should not drink alcoholic beverages during pregnancy because of the risk of birth defects. (2) Consumption of alcoholic beverages impairs your ability to drive a car or operate machinery, and may cause health problems.” The words “GOVERNMENT WARNING” must appear in all capital letters in bold type. The remainder of the statement need not be in bold type. The statement must appear a continuous paragraph.

The name and address on each container of American wine shall state either “bottled by” or “packed by” followed by the name of the bottler or packer and the address of the place where the wine was bottled or packed.

  • “Bottled For” Designation. In addition to the name and address of the bottler or packer, the label may also state the name and address of any person for whom the wine was bottled or packed as long as the name is preceded by one of the following phrases: “bottled for,” “packed for,” or “distributed by.”
  • “Produced By” Designation. The wine label may state that the wine was “produced by” or “made by” a particular winery if: (1) not less than 75% of the wine was made at the stated address; (2) the stated winery changed the class or type of the wine by addition of alcohol, brandy, flavors, colors, or artificial carbonation at the state address; or (3) the winery produced sparkling wine by secondary fermentation at the stated address.
  • “Blended By” Designation. The wine label may state that the wine was “blended by” a particular winery if the named winery mixed the wine with other wines of the same class and type at the stated address.
  • Other Designations. The wine label may state that the wine was “cellared,” “vinted,” or “prepared” at the named winery if the wine was subjected to industry acceptable cellar practice at the stated address.

The net contents of a wine container must be stated on a label in metric units of measure. Wine containers may only be bottled in certain sizes. Be sure to check to ensure your bottle is an acceptable size.

Examples: 750 ML; 1 Liter

All wine contains some natural sulfites. Sulfites are also commonly added to wine for preservation purposes. If your wine contains 10 or more parts per million of sulfites, your label must include a sulfite declaration. If you do not want to include the declaration of sulfites for wine containing less than 10 parts per million of sulfites, you will need to submit your product to the TTB for a sulfite analysis pre-COLA evaluation.

Example: Contains Sulfites

Nearly all wine sold in the United States must be labeled with a government-approved label. To obtain government approval, you must submit an application for a certificate of label approval (“COLA”) to the TTB. You cannot submit the application until you receive a Winery Permit [LINK: Opening a Winery] allowing you to manufacture or sell your product. You must also prepare a sample label to submit with the application. The easiest and most efficient way to submit a COLA application is to create an account with COLAs Online which you can access through the TTB website.

To file a wine COLA application, you must first establish that the person completing the application has the authority to interact with the TTB on your behalf. If the person completing the application was not listed as someone with such authority on your permit application, you must submit additional documentation to the TTB authorizing the person to complete the application. If the person filing the COLA application was listed as having such authority, skip to Section 4 of this article.

The TTB recognizes two types of signing authority.

The first is authority a person has because they are a member of an LLC or officer of a corporation. (Go here for more on selecting the appropriate kind of business entity.) If the person completing the COLA application is a member of your LLC or officer of your corporation, but was not listed as having signing authority when you filed your alcohol permit application, someone else who already has TTB-recognized authority to act on your company’s behalf must execute and file a TTB form called a Signing Authority giving the person the authority to act on your behalf. The TTB Signing Authority form is available on the TTB’s website. This type of form is also appropriate if you wish to have a company employee interact with the TTB.

The second type of singing authority is a Power of Attorney. The Power of Attorney form is the appropriate form to file if the person completing the application is acting on your behalf in a representative capacity, such as the company’s attorney or accountant. The form is also available on the TTB’s website. Again, someone at the company who the TTB has already recognized as having authority to act on the company’s behalf must sign the Power of Attorney.

Once you’ve completed the appropriate form authorizing someone to act on the company’s behalf, you must amend your Winery Permit to include the new authority. The easiest way to amend your application is to log into your TTB Permits Online Account and select the “Create Amendment” option next to your approved application record. You cannot register to use COLAs Online on the company’s behalf until the TTB approves the amendment.

Once you have completed steps 1-3 above, or determined you can skip them, you may register on COLAs Online to file the COLA application. Registration is fairly straightforward. You are required to provide information such as your contact information, permit number, and date of permit issuance. Once you’ve completed each of the required steps, you can submit the registration request. The TTB may take up to 20 days to verify your authorization, but generally it takes much less time.

Once the TTB verifies your authority to do so, you can move forward with filing your COLA application. To complete the application, you must upload an image of your label. The label must be a JPG or TIFF file and cannot exceed 750 KB in size. Along with a copy of your label, you will need to provide the TTB with the following information about each label:

  • your DBA/Trade Name (if any);
  • your brand name;
  • your product’s fanciful name (if any); and
  • the size of the actual printed label.

Once you’ve submitted your application, a TTB officer will usually respond within two weeks. The TTB provides up-to- date processing information for label application on its website.

The tricky part of filing a COLA application is making sure that the label meets all federal regulations. This requires a careful review of the regulations regarding labeling and may also require you to allow the TTB to analyze a sample of your product. For more information about labelling requirements and TTB sample analyses see the following related articles:

Under the law, wine containers must be labeled with government-approved labels before they can be sold. In some cases, before the TTB will accept a certificate of label approval (“COLA”) application, it will require applicants to submit information about their product and may also require a product sample for laboratory testing. The TTB refers to these submissions as pre-cola product evaluations.

Formula evaluations are not required for all wine.

The TTB recognizes several different classes of wine. To be in a particular “class,” wine must meet the TTB’s standard of identity for wine in that class. For example, Grape Wine is an extremely popular class of wine. Wines such as merlot, pinot noir, and pinot grigio are examples of wines included in the Grape Wine Class. At a very basic level, wine is in the Grape Wine Class if: it is produced through the normal alcoholic fermentation of the juice of grapes with or without the addition of sugar and is below a maximum allowable volatile acidity. Wine makers making wines that fall within the Grape Wine Class are not generally required to submit a pre-cola formula evaluation.

Formulas are required for some classes of wine recognized by the TTB and for wine that does not fall within any of the recognized class (known as a specialty wine). Prior to applying for COLA [LINK TO ARTICLE RE APPLYING FOR A WINE COLA], you will need to determine whether your wine falls within a class, and if so, whether it is a class for which a pre-cola formula evaluation is required. This information is available on the TTB’s website.

Formula Evaluations.

Domestically produced alcohol products are most likely to be subject to a type of pre-cola product evaluation referred to as formula evaluations. The TTB website lists the wine, malted beverage, and distilled spirits that require formula evaluations before a COLA application can be submitted.

For malt beverages, the TTB most commonly requires a formula evaluation for specialty products such as flavored beer. For example, a formula must be filed for beer flavored with chocolate extract or syrup.

Information you must submit for the pre-cola evaluation.

If you are required to submit a pre-cola formula evaluation, you can do so electronically on the TTB’s website. At a minimum, you will need to provide information such as:

  • The name, address, and winery number of the proprietor;
  • The class and type of the wine;
  • The kind and quantity of each and every ingredient used in the wine;
  • All flavoring and blending materials used in the wine, if any, including:
    • The name of the flavor or blender;
    • The name of the manufacturer;
    • The manufacturer’s product number, if any;
    • A drawback formula number, if any. When a flavor manufacturer uses alcohol in a product that is approved as being unfit for beverage purposes, it is given a drawback formula number and the manufacturer can claim a return on most of the excise tax it paid;
    • Date of approval of the nonbeverage formula;
    • Alcohol content of the flavor or blender, if any;
    • A description of any coloring material contained in the flavor or blender; and
  • The step by step sequence used to produce the wine.

Documentation you may need to submit with the pre-cola evaluation.

A flavored ingredient data sheet (“FID”) is a spreadsheet that includes information about ingredients used in compound flavors. A compound flavor is a flavor consisting of multiple ingredients that are combined to produce a particular taste. If you use a compound flavor purchased from a flavor manufacturer in your product, you will need to submit a FID with your formula. The flavor manufacturer should be able to provide you with a FID when you purchase the flavors.

A limited ingredient calculation worksheet is a tool used to calculate the total amount of limited-use ingredients in your product. The limited ingredient calculation worksheet should only be used for products containing a compound flavor. Most of the time, you’ll be able to use the information provided in your FIDs to complete the limited ingredient calculation worksheet. You can obtain a limited ingredient calculation worksheet on the TTB website.

An ingredient specification sheet lists the contents of an ingredient used to complete your product. When submitting your formula, you should include a specification sheet for each ingredient that is made from more than one component (with the exception of compound flavors for which you should submit a flavored ingredient data sheet). For example, if your product is made from a juice made of sugar, water, and lemon, you will likely need to submit a specification sheet listing those components. You should be able to obtain the ingredient specification sheet from the ingredient manufacturer.

Other pre-COLA evaluations -- Sulfite Exemption.

If your wine contains 10 or more parts per million of sulfites, your label must include a sulfite declaration. If you do not want to include the declaration of sulfites for wine containing less than 10 parts per million of sulfites, you will need to submit your product to the TTB for a sulfite analysis pre-COLA evaluation.

Wine containers in the U.S. must be labeled with government-approved labels before they can be sold. In some cases, before the TTB will approve a Certificate of Label Approval (“COLA”) application, it will require applicants to submit information about their product and may also require a product sample for laboratory testing. The TTB refers to these submissions as pre-cola product evaluations. One type of pre-cola product evaluation important to wine makers is the sulfite analysis.

Sulfites are chemical compounds that naturally occur in some foods and beverages, including wine. Wine makers often add more sulfites to wine during production to speed up fermentation and to act as a preservative. Some people may be allergic to sulfites.

All wines produced for sale in the United States that contain 10 or more parts per million of sulfites must be affixed with labels including the phrase “Contains Sulfites.”

If your label includes the phrase “Contains Sulfites” you are not required to submit your wine for a sulfite analysis. However, wines that contain less than 10 parts per million of sulfites can obtain a sulfite waiver through the TTB allowing the label to either: (1) omit the “Contains Sulfites” language: or (2) include a statement such as “Contains Less Than 10 Parts Per Million Sulfites.” To obtain a sulfite waver, you must submit a sample analysis of your wine to the TTB or to a TTB-certified laboratory and submit a proof of sample analysis to the TTB with your application for a COLA. A list of TTB-certified laboratories is available on the TTB website.

Samples submitted for sulfite analysis must be:

  • At least 750 ml in volume;
  • Identified by vintage, batch, or lot, and class and/or type designation (for example, merlot); and
  • Accompanied by a transmittal letter requesting the analysis that identifies the name of the submitter and the location to which the results should be sent.

If you plan to send your sulfite analysis to the TTB directly, send them to the following address along with the required information described above:

Alcohol and Tobacco Tax and Trade Bureau
Compliance Laboratory
490 north Wiget Lane
Walnut Creek, CA 94598

Learn More

For more information on labeling regulations and approvals, see our resource pages:

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