ATF Ruling 73-6

In view of the expanding use of grape type designations on labels of imported Spanish wines, the Bureau of Alcohol, Tobacco and Firearms recognizes a need for clarification of its position in respect to varietal designations. Such clarification appears necessary since there is some doubt as to whether grapes for which the following varietal designations are claimed are actually grown in Spain in sufficient quantities to support the volume of wine exported to the United States:

Cabernet Sauvignon


Grenache Rose

Johannisberg Riesling

Pinot Chardonnay



Chenin Blanc

Gamay Beaujolais

Gray Riesling

Pinot Blanc

Pinot Noir

Sauvignon Blanc


Regulations in 27 CFR 4.23, which implement the provisions of 27 U.S.C. 205(e), "Labeling", permit the use of a name indicative of a grape variety as the type designation of a grape wine if the wine derives its predominant taste, aroma, and characteristics, and at least 51 percent of its volume, from the variety of grape indicated on the labels.

In view of the doubt that some Spanish wines are eligible for certain varietal designations, it is held that Spanish wines labeled with grape type designations may not be released from customs custody after April 22, 1973, for sale in the United States unless each shipment thereof is accompanied by a certified statement issued by an authorized official of the Spanish government's Ministry of Agriculture that the wines in the shipment were, in fact, produced in compliance with the laws of Spain regulating the production of such wines for home consumption (but, from at least 51 percent of the particular variety of grape indicated by such designation) and that the predominant taste, aroma, and characteristics were derived from such grapes.

If importers find, as to any particular certificates of label approval they now hold, that they will not be able to obtain satisfactory proof as discussed above, they should surrender such certificates for cancellation.

27 CFR 4.23 and 4.45.