February 12, 2020
Number: 2020 – 1
Updates to TTB Guidance 2016-2: Pre-COLA Product Evaluations For Wine Products and TTB Guidance 2017-5: Formula Approval with Laboratory Sample Analysis
To: Proprietors of Bonded Wineries, Bonded Wine Cellars, Breweries, Importers, and Others Concerned.
1. Purpose.
This industry circular announces updates to two TTB public guidance documents pertaining to formula and laboratory sample analysis requirements for beverage and nonbeverage wines.
TTB G 2016-2, “Pre-COLA [Certificate of Label Approval] Product Evaluations for Wine Products,” dated September 29, 2016, is superseded by new TTB G 2016-2A.
TTB G 2017-5, “Formula Approval with Laboratory Sample Analysis,” dated October 6, 2017, which contains a list of products that require formula approval with laboratory sample analysis, is superseded by new TTB G 2017-5A.
2. Background.
In accordance with TTB regulations, industry members are required to submit formulas for review by TTB prior to the production or importation of certain alcohol beverages, and before the domestic producer or U.S. importer may apply for label approval. In some cases, TTB also requires the submission of a sample for laboratory analysis.
TTB maintains three (3) guidance documents, one each for wine, distilled spirits, and beer/malt beverages, which contain charts reflecting the current formula requirements for that commodity. The charts are provided as general guidance, and are updated periodically by TTB as requirements change. Please note that pursuant to its authority under 27 CFR 4.38(h), TTB may require a formula or other pre-COLA analysis for a specific wine even though no such requirement is indicated on the chart.
In 2017, TTB issued guidance document 2017-5, “Formula Approval with Laboratory Sample Analysis.” This guidance document explains when an industry member must submit a sample for laboratory analysis in addition to applying for formula approval. Among other things, the guidance document contains a list of alcohol beverages that require both laboratory sample analysis and formula approval. That list is updated by TTB as changes are made to TTB policy regarding formula with sample analysis requirements.
3. Revisions to TTB G-2016-2.
TTB is announcing the following changes to TTB Guidance 2016-2:
- The title of the document is changed to, “Wines that Require Either Formula Approval or Formula Approval with Laboratory Sample Analysis.”
- The guidance number is updated to 2016-2A.
- The laboratory sample analysis requirement for imported imitation wine is eliminated (a formula is still required).
- Ice wine is deleted from the list to reflect TTB policy.
- The list has been revised to eliminate references to over 170 classes or types of wine that do not require either formula approval or formula approval with laboratory sample analysis. This makes the list much shorter and easier to read.
- The list is updated to include existing formula and sample requirements under 27 CFR part 24 for several categories of domestic wines. The previous list focused solely on labeling classifications under 27 CFR part 4.
- The list now includes two categories of wines and wine products that are not for sale or consumption as beverage wine. The first category is wines or wine products that are unfit for beverage use (such as vinegar and salted cooking wines) and thus may not be sold or consumed as beverage wine. The second category is blending wines (such as heavy bodied blending wine) that are not for sale or consumption as beverage wine, but may be used in the production of certain beverage wines.
- The list has also been amended to add certain beverage wines that are not labeled with their part 24 classification name (such as special natural wine, which is typically labeled with a statement of composition unless it falls within the definition of an aperitif or retsina).
4. Revisions to TTB G 2017-5.
TTB is announcing the following changes to the document that contains the list of alcohol beverages that require formula approval with laboratory sample analysis:
- The guidance number is updated to 2017-5A.
- Imported imitation wine is deleted (a formula is still required).
- Clarifying language is added that does not make any substantive changes to the requirements.
Questions. If you have any questions concerning this industry circular, please contact the Alcohol Labeling and Formulation Division at 1-866-927-2533 or use the Alcohol Labeling and Formulation Division (ALFD) Contact Form.
Mary G. Ryan
Acting Administrator
Alcohol and Tobacco Tax and Trade Bureau
Page last reviewed: February 12, 2020
Page last updated: February 12, 2020
Maintained by: Alcohol Labeling and Formulation Division