A wine label serves myriad purposes. At its essence, a label distinguishes one vineyard’s brand and related products from its competitors. The design of the label itself—whether it’s the logo, font, color scheme, or imagery—are all marketing tools.
While each wine label is unique, they all share uniform traits. Aside from aesthetics, the beverage label must also convey important information that the consumer needs to know as they make their purchasing decision, such as alcohol content and nutrition labeling.
That’s because there are specific wine labeling requirements that every brand must adhere to. So what is required on a wine label? The experts at Wildpack have you covered.
Who Is Responsible for Setting Wine Labeling Requirements?
Within the United States, practically every single product that’s sold to consumers will be subject to regulations in some shape or form. Naturally, products that pose a greater risk to consumers’ health and safety will have more stringent regulations. The wine industry is no exception.
Today, there are various laws that regulate all aspects of winemaking—from production and sourcing to packing, labeling, and selling. This serves several purposes, including:
- Preventing wine fraud
- Protecting brand integrity
- Limiting allowed additives
- Thwarting false or misleading statements
- Ensuring quality
- Maintaining safety
- Precluding unfair trade practices
To that end, the United States Alcohol and Tobacco Tax and Trade Bureau (TBB) is charged with the taxation, importation, and labeling of alcohol within the states. And the rules pertaining to grape wine labels are published in the following documents:
- Title 27 of the Code of Federal Regulations (“CFR”)
- TTB’s “Beverage Alcohol Manual” (“BAM”) for wine
- Laws, Regulations, and Public Guidance
For wine products that contain more than 7% alcohol by volume, the TTB must approve all wine labels before the products may be released to consumers. In the vast majority of cases, this must include a Certificate of Label Approval (COLA). Additionally, some types of products are also subject to a pre-COLA review.
For wine products that contain less than 7% alcohol by volume, the Food and Drug Administration has jurisdiction. Additionally, a winemaker may also be subject to state and local laws.
Sounds complicated, right? That’s because it is.
Even for experienced brands, legal compliance can be a demanding task. That’s why it’s crucial that you only work with an accomplished copacker or beverage sleever, such as Wildpack. Our team is intimately familiar with the various rules and governing the production and labeling of all types of wine.
Wine Labeling Requirements for Products with More than 7% Alcohol by Volume
Does your wine product contain more than 7% alcohol by volume?
If so, it’s subject to 27 CFR 4.32 and 4.34, in addition to the health warning statement outlined in 27 CFR part 16. Requirements include six components:
#1 The Brand Label
The brand label is the part of the label that typically houses the brand’s unique design logo as well as the name under which a grape wine or the product line of grape wines is marketed as. This tends to be the most prominent piece of information on a label, but there are no restrictions pertaining to which side of a bottle or can that this label appears.
Brand Name
A brand’s name is typically attributed to the winery or the specific winemaker. However, the wine producer could also be listed as the brand name. In terms of type font, there are size requirements for a brand name:2
- At least 1 mm for containers 187 ml or less
- At least 2 mm for containers larger than 187 ml
The name needs to be legible, appear on a contrasting background, and be clearly separate from any of the additional information. It can’t be misleading in that it “creates a misleading or erroneous impression or inference as to the age, origin, identity or other characteristics of the wine.”
Appellation of Origin
New world and old world wines each have a different labeling requirement in terms of location, especially since certain regions are well-known for the quality or characteristics of their wine.
Per the TTB, your wine’s brand label will likely require an appellation of origin if it has a:
- Vintage date
- Varietal designation
- Type designation of varietal significance
- Semi-generic designation
- “Estate bottled” claim
- Product name qualified with the word “brand”
Class and Type Designation
Wines can be broken down into class and type. Those specifics provide consumers with a quick informational reference point. Therefore, such a designation must be included on a brand label.
- Class is the overarching category of wine. This may include:
- Grape wine
- Citrus wine
- Fruit wine
- Sparkling wine
- Carbonated wine
- Aperitif wine
- Retsina wine
- Substandard wine
- Every class will have specific types of wine. For instance, the grape variety class can include broad descriptions like red wine, rose wine, pink wine, white wine, and amber wine. Or, it can be a more detailed type of wine that’s tied to a specific region like Chianti, Bordeaux, or Champagne.
Percentage of Foreign Wine
If your wine is a blend of American and imported wine and the label mentions the presence of the foreign wine, that specific percentage must appear clearly on the brand label.
Size requirements include:
- At least 2 mm for containers larger than 187 ml
- At least 1 mm for containers of 187 ml or less
#2 Alcohol Content
One of the more important safety designations for any wine label is the alcohol percentage indicator. This expresses the amount of alcohol in the wine in terms of the percentage of alcohol by volume (ABV).
Does your wine contain more than 14% ABV?
If so, you’re required to make a numerical alcohol percentage statement. This can be expressed by a specific number or by a range. For instance, a label may read “Alc. 16% by Vol.” or “Alc. 18% to 20% by Vol.”
Does your wine contain between 7%-14% alcohol by volume?
If so, it either needs to have a numerical content statement or a type of designation such as “table wine” or “dessert wine.”
#3 Color Ingredient Disclosures
Some brands give their wines additives to enhance their color. You’re required to provide a “Contains [additive name]” designation if your wine includes one of three additives:
- FD&C Yellow No. 5
- Cochineal extract
- Carmine
#4 Health Warning Statement
In 1988, the Alcoholic Beverage Labeling Act required that any alcoholic beverage label should have the following statement:
“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.”
Sulfite Declaration
If your wine contains sulfites or sulfite agents at a level of 10 or more parts per million, a sulfite declaration must be included on the product label. This declaration may be added to the end of the health warning statement, but needs to be bolded and spaced apart from the original warning.
#5 Name and Address
American wines need to provide the name and address of whoever was tasked with the bottling, canning, or packing of the beverage. This must include both the city and state.
For example, if you worked with Wildpack, your wine can would list one of our 8 locations:
- Baltimore, MD
- Baltimore, MD
- Las Vegas, NV
- Las Vegas, NV
- Marietta, GA
- Sacramento, CA
- Longmont, CO
- Grand Rapids, MI
#6 Net Contents
The final FDA requirement is the net contents. This states how much wine is in the container. Most canned wines will contain 250-375 mL of wine.
Wine Labeling Requirements for Wines with Less than 7% ABV
Although less common, some wines contain less than 7% ABV. In such cases, the wine is neither subject to the labeling rules of the Federal Alcohol Administration (FAA) Act, nor does it require pre-approval from the TTB.
They are, however, required to follow USFDA wine labeling requirements. In that regard, the FDA stipulated that this type of wine still needs to follow many of the same labeling procedures, including:
- The name and address of where the wine is bottled, canned, or packed
- The brand name (if that differs from the name and address above)
- Net contents of the container
- Designation of the kind of wine
- Alcohol content as a percentage of volume
Wildpack—Wine Canning Specialists
Properly labeling your wine is a vital part of winemaking. It’s not only a marketing and branding tool, it also conveys important information that consumers need to be aware of. Failure to comply with the rules and regulations can have stiff penalties, including a $21,633 penalty for each day after a violation has been discovered.
For that reason, you must be discriminating with who you select as your sleeving and canning partner. They should be well-versed in all of the requirements and experience in compliance with regulations.
That’s why Wildpack is an obvious ally in canned wine production. We offer co-packing, sleeving, warehousing, and third-party logistics services to established and emerging wine brands.
Interested in learning more? Contact us today to receive a free quote.
Sources:
eCFR. Title 27 of the Code of Federal Regulations. https://docs.google.com/document/d/1ceSmZGlKAvWToqxDp-0S40ut90WxiY1HaPjUhZGGrZs/edit#
TTB. Beverage Alcohol Manual for Wine. Mandatory Label Information. https://www.ttb.gov/images/pdfs/wine_bam/c1-mandatory-label-information.pdf
TTB. Laws, Regulations, and Public Guidance. https://www.ttb.gov/laws-regulations-and-public-guidance
TTB. Wine Labeling: Appellation of Origin. https://www.ttb.gov/labeling-wine/wine-labeling-appellation-of-origin
TTB. Wine Labeling: Brand name. https://www.ttb.gov/labeling-wine/wine-labeling-brand-name
