"Reserve." "Old Vine." "Proprietor's Blend." These are some of the most resonant words on a wine label, Yet compliance-wise, they're vaporous prose. The TTB has no definition for any of them. Anyone can print them on any wine.
Meanwhile, the plainer-sounding terms are policed to the percentage point:
- Varietal (e.g., Cabernet Sauvignon) → at least 75% must be that grape
- Vintage date → 95% from the stated year, if the label carries an AVA
- "Produced by" → the winery fermented at least 75% of the wine (not the same as "Bottled by")
- Estate Bottled → grown, made, and bottled by one winery, on its own land, in one AVA. All or nothing.
The rejections come from treating these two categories the same way: leaning on a marketing word as if it were a credential, or using a defined term you haven't earned. "Estate Reserve" on a wine that doesn't qualify as Estate Bottled is a fast route to a REVIEW flag.
One caveat worth knowing: unregulated doesn't mean anything goes. Every label is still subject to 27 CFR 4.39's ban on misleading claims. "Reserve" is fine. "Reserve" staged to imply an age or grade you can't back up is not.
New blog post defines the line between marketing language and regulated claims, with the CFR citations behind each one. COLAClear can help with the vetting. Link to the full article: https://www.colaclear.com/blog/wine-label-terms-regulated-vs-marketing/
July 14, 2026
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