Rev. Ruling 55-595

Labeling Wine Bottled by a Taxpaid Wine Bottling House for Another Person

The Taxpaid Wine Bottling House Regulations do not authorize the operation of a taxpaid wine bottling house under alternating proprietorships. Accordingly, such operations may not be permitted. However, the proprietor of a taxpaid wine bottling house may, upon amendment of his basic permit issued pursuant to the Federal Alcohol Administration Act and of his qualifying documents required by Subpart E of the Taxpaid Wine Bottling House Regulations, bottle wine under trade names. Any such authorized trade name may then be shown on bottle labels and on cases as the name of the proprietor. While the bottler (proprietor) may not use a trade name the operating name of another dealer and may not qualify a trade name registered by another dealer, arrangements may be made between the bottler and another dealer whereby the bottler would qualify a trade name which would be used only on labels of wine to be sold by such other dealer. The label may show, in addition to such trade name but not in lieu thereof, the name and address of the dealer for whom the wine is bottled or packed, immediately preceded by the words "Bottled for," "Packed for ... .. Distributed by," or other similar statement, as authorized by section 35 of Regulations No. 4. However, the trade name of the bottler may not be similar to the name of the person or firm for whom bottled (unless they are related in ownership), since an erroneous impression may be created that the companies are related entities when such is in fact not the case.

26 U.S.C. 205; 27 CFR 231.30