TTB Requests Comments on Wine Labeling Requirements

by Michael Kaiser


TTB has issued Notice 160 (read it here) Proposed Revisions to Wine Labeling and Record Keeping Requirements. The notice proposes to amend the labeling regulations to provide that any standard grape wine containing 7% or more alcohol by volume that is covered by a certificate of exemption from label approval may not be labeled with:

  • A varietal designation
  • A type designation of varietal significance
  • A vintage date
  • An appellation of origin, unless the wine is labeled is in compliance with the standards set forth in the regulations.

If a winery is choosing to file for an exemption from label approval, under this proposal they will only be allowed to use the descriptors on their labels if the wine in question meets the current labeling requirements. For American viticultural areas (AVA) the requirements are:

  • The AVA must be approved for use by the TTB
  • 85% of the wine must be made from grapes grown in the AVA
  • The wine must be fully finished in the state where the AVA is located

That is, a winery may use the AVA with a label filed as an exemption if they have purchased bulk wine that has been finished in the state where the AVA is located and bottled it elsewhere.

The TTB is taking this action in response to concerns raised by wine industry members and members of Congress regarding the accuracy of label information on certain wines covered by certificates of exemption from label approval. The are requesting public comments until August  22, 2016. Comments can be submitted the following ways:

  • Internet: (via the online comment form for this notice as posted within Docket No. TTB–2016–0005 at ‘‘,’’ the Federal e-rulemaking portal)
  • U.S. Mail: Director, Regulations and Rulings Division, Alcohol and Tobacco Tax and Trade Bureau, 1310 G Street NW., Box 12, Washington, DC 20005
  • Hand delivery/courier in lieu of mail: Alcohol and Tobacco Tax and Trade Bureau, 1310 G Street NW., Suite 400, Washington, DC 20005


Questions? Contact Michael Kaiser, Director of Public Affairs,

WineAmerica is the national voice the American wine industry. Based in Washington, D.C., WineAmerica represents wineries in 43 states and leads a coalition of state and regional wine and grape associations.  As an industry leader, WineAmerica encourages the dynamic growth and development of American wineries and winegrowing through the advancement and advocacy of sound public policy.

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