Wine Labels: Labeling Requirements With Respect to Both Metric
Standards of Fill and Statements of Sugar Content For Late
Harvest-Type Wines
Proprietors of Bonded Wine Cellars, Taxpaid Wine Bottling
Houses, Importers and Others Concerned:
Purpose. The purpose of this circular is three-fold:
- To remind industry members that, in accordance with 27 CFR
4.73, the effective date for conformity with metric standards of
fill for wine is January 1, 1979;
- To advise industry members that labels which have been
approved for use on containers for wine may not require new
certificates of label approval or certificates of exemption from
label approval when revised only to bring into conformity with
metric standards of fill as required by 27 CFR 4.73; and,
- To advise industry members that labels which have been
approved for use on containers for late harvest-type wine may not
require new certificates of label approval or certificates of
exemption from label approval when revised only to change sugar
content.
Metric Standards of Fill. To avoid any misunderstanding, this
circular is intended to make it clear that the provisions of 27
CFR 4.73, relating to metric standards of fill for wine, will be
applied, without exception, after December 31, 1978.
In accordance with 27 CFR 4.46, wine imported in original containers
not conforming to metric standards of fill shall not be released
from customs custody after December 31, 1978, unless the wine is
being withdrawn from a customs bonded warehouse into which it was
entered on or before December 31, 1978; or unless such wine is
accompanied by a statement certifying that the wine was bottled
or packed prior to January 1, 1979. This statement may be signed
by any official authorized by the appropriate foreign government
to issue such certification.
After December 31, 1978, containers for wine may bear statements
of net contents in addition to the required metric net content
statement provided such optional statements represent an equivalent volume and are not in any way misleading to the consumer. Additional
statements of net contents may appear separate and apart from, rather
than in direct conjunction with, the required metric net content state-
ment but may not be more conspicuous than the required statement.
For example, if a wine container shows the net contents in accordance
with 27 CFR 4.73 as "750 ml," an additional statement such as "75 cl,"
".75 L," "25.4 fl. oz.," etc., may appear anywhere on the container
provided its appearance is not more conspicuous than the required
"750 ml" nor is in any other manner misleading to the consumer.
Labels Changed to Conform with Metric Standards of Fill. New certifi-
cates of label approval or certificates of exemption from label
approval are not required for previously approved labels being changed
only to comply with metric standards of fill for wine as required by
27 CFR 4.73.
Such changes are limited to the substitution of the required metric net
content statement in lieu of nonmetric net content statements, the
addition of optional net content statements as described above, and the
deletion of nonmetric net content statements including, after
December 31, 1978, those required under 27 CFR 4.37. Such changes will
not require resubmission for label approval provided they are not mis-
leading to the consumer or result in the rearrangement, obliteration,
obscuration, or any other revision of mandatory information required
under the Federal Alcohol Administration Act.
Statements of Sugar Content on Labels for Late Harvest-Type Wines. New
certificates of label approval or certificates of exemption from label
approval are not required for previously approved late harvest-type wine
labels when only sugar content is being changed.
Such changes must comply with the provisions of ATF Ruling 78-4 and are
limited to the sugar content of the grapes at time of harvest and/or
the residual sugar content of the finished wine and/or the units being
used to describe these sugar contents.
Such changes will not require resubmission for label approval provided
they do not mislead the consumer or result in the rearrangement,
obliteration, obscuration or any other revision of mandatory informa-
tion required under the Federal Alcohol Administration Act.
Inquiries. Inquiries concerning this circular should refer to its
number and be addressed to the Assistant Director (Regulatory
Enforcement), Bureau of Alcohol, Tobacco and Firearms, 1200 Pennsylvania
Avenue, NW., Washington, DC 20226

Acting Director
GPO 934-840 |