When people talk about winemaking being an art and a science, they often forget to mention the part about how much compliance is involved! (Sometimes they forget to mention how much cleaning is involved as well, but that’s for another article.) That is, until it’s time to bottle your wine. Like most consumer packaged goods, every bottle of wine has a label that is subject to regulation. This has its history in consumer safety and transparency. The governing body for wine production is the federal Tax and Trade Bureau (TTB). There is much compliance and regulation around wine production, but one very visible part is the acquiring of a Certificate of Label Approval (COLA). This is the certificate that verifies the information on your wine label. Submission, and approval of this, are required in order to bottle your wine. Here we’ll go into some of the most noteworthy and regulated aspects of a wine label. As always, for the most current and specific information, consult your local compliance agency, or contact the TTB.

TTB has an excellent Permits Online portal to allow this carried out efficiently online. To use this, you’ll just need to set up an account.

What type of information is needed for a wine label?

Wine is a fermented beverage that it is made from a variety of fruits (we work with grapes, so we’ll default to that for this article). Things relevant to consumers in the world of wine are grape variety (Cabernet Sauvignon or Chardonnay, for example), geographical region the grapes were sourced from, and vintage of harvest (if applicable). Thus, wine labeling includes these items in addition to general branding, ownership, and government warning statements. Please note, this article relates to wines made in the U.S.; additional information may be required for imports.

Wine Label Components 

The Checklist

Before we get into specifics of where the information needs to go, let’s look at the basic components required to be present on a label:

• Brand Name: This is the name of your wine. As you would guess, the wine must have a designated brand name and it must be displayed on the label.
• Class and Type Designation: A sample Class is “table wine” or “Red Wine.” Type of wine can suffice for this, for example “Pinot Noir.”
• Alcohol Content: Display the alcohol by volume (ABV) as a percentage. This must be indicated to the tenth decimal place.
• Net Contents: The volume of the wine in metric units (e.g., milliliters) or U.S. units (yes, Fluid Ounces are allowed, but rarely seen).
• Government Warning: Include the government warning statement regarding the risks of alcohol consumption.
• Sulfite Declaration: If the wine contains sulfites in excess of 10 parts per million, a sulfite declaration is required.

First Things First: Trade Names and Bottler Statements

One critical step before filing is to ensure your Brand Name (trade name) is added to your basic permit. This is done by amending your basic permit. This assures that the TTB is aware of your ownership (or permission to use) said names or fictitious business names in your filings. This is the case if you are operating at your own facility or as an alternating proprietor at a custom crush facility. However, if you are operating under someone else’s license, they will do this on your behalf. If so, they will also need to submit an “Authorized Bottler” letter written by you, the owner of the brand, that allows them to bottle with the indicated brand names and also add them onto their permit for the time being. With this, when they TTB sees your COLA come through the office with your brand and business names, it can be verified that those names are in place on your TTB Basic Permits.

Now that you have the Brand and Trade names added, you can decide how the bottler statement will read. This is a declaration that indicates who is carrying out the bottling of the wine. This often indicates the owner of the wine, but it does not necessarily mean that. Below are some samples:

Produced and Bottled By ______

This declares that at least 75% of the grapes used in the production of this wine was fermented and bottled by the stated producer and address. This is often seen as a prestigious designation and some customers appreciate this added level of traceability from the producer.

Cellared and bottled by _______

This term is generally used for wine that is aged in the cellar by the listed producer and address, but does not require fermentation by said producer.

Vinted and bottled by _______

This term also coveys that there may have been some winemaking activity that takes place in the cellar and the term does not inform a level of time that the wine would have spent at a given producer.

Is there such thing as a front or back label?

Next, let’s define a common term. As consumers, when we look at a wine bottle we have an intuitive sense as to which label is the front and which is the back. This may be true, but like most things, there must be a set of information that makes this definable. The TTB makes the distinction by giving the “Front” label the official classification as the Brand Label. Thus, we have the Brand/Front and the Back label. It is worth noting that years ago the TTB used to only classify labels as the Front and Back label, and certain information was required to be on the front vs the back. This led to wineries submitting the front label as the back label to have more creative flexibility. While the former designation was perfectly legal, the current regulations allow for more clear communication and understanding.

Front or back label? Though seemingly obvious, the answer may not be as simple as you think. The definition relates to the information contained on the label rather than the design.

While the TTB is flexible in regards to where some of this information is placed on the various labels, there are three things that must appear on the same label. These are the Alcohol Content, the Brand Name and the Class/Type. Our friends at Holtzclaw Compliance share the memorable acronym “ABC” as the acronym for these three! The other information can be placed on either label(s) as they benefit your design.

Time to File!

Now that you are ready to file your COLA, you may submit it to the TTB. You can file your COLA by accessing the current forms on the TTB site. TTB also has an excellent portal for submitting all actions listed in this article online. To access this you will just need to set up an online account.

If you are making your wine at a Custom Crush facility, you have different options. If you are an Alternating Proprietor customer, you may file your own COLA. If you are making your wine under the license of the facility, you will need to coordinate with them first. The facility can file for you (this is often the easiest option), or you can file on your own—but in order to do so, you will need to fill out a Power of Attorney form so that you can file for approval under their license.

The TTB is remarkably fast and if filed online there is a good chance you will have a response within a few days. If there are changes or corrections to be made, that will be communicated as well. The TTB is very helpful in communicating and facilitating this process.

A sample view of the form utilized to submit for your certificate of label approval.

Additional Terms and Considerations

• Estate Bottled: Vineyards that supplied the grapes for the bottled wine is owned or controlled by the winery and located in the same viticultural area as the wine is bottled.
• Vintage: Must be 95% from said vintage.
• Single Vineyard designation: Must be from stated vineyard.
• American Viticultural Area (AVA): Must contain 85% of fruit from the indicated AVA. (Note some states may have more specific labeling laws)
• Font sizes: 2mm or larger for containers larger than 187ML. The smallest typed letter in the sentence is subject to this rule.
• Embossing of the volume into the bottle can suffice for the net contents statement.

Many things are able to be changed without applying for a new COLA. That list can be found here. This increases efficiency for both you and the TTB.

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