For domestic products, the name and address statement must include the name (or trade name) and address (city and State) of the bottler of the malt beverage, as shown on the brewer’s notice.
The bottler's principal place of business may be shown instead of the actual place where the product was bottled, if the address shown is a location where bottling operations take place. TTB may disapprove the listing of a principal place of business if its use would create a false or misleading impression as to the geographic origin of product. A bottler may also include the place where the malt beverage was bottled in a listing of the locations of breweries owned by the brewer. See 27 CFR 7.66.
Optional terms may also be used if desired, such as “brewed and bottled by,” “bottled for,” etc., as discussed below.
For imported malt beverages, see Name and Address (Imports).
On the label above, “Malt & Hop Brewery,” and “Hyattsville, MD” meet the requirements of the bottler’s name and address statement.
Where should the name and address statement be placed on the product?
The name and address must appear on the label, but may also be blown, embossed, or molded into the container as part of the process of manufacturing the container. See 27 CFR 7.63(a)(4).
What are the formatting requirements for the required name and address statement?
Type size:
- Minimum 1 mm for containers of 1/2 pint or less
- Minimum 2 mm for containers larger than 1/2 pint
Note: The minimum type size applies to each numeral or letter in the statement, including both uppercase and lowercase letters. See 27 CFR 7.53.
Legibility:
- Must be readily legible under ordinary conditions;
- Must appear on a contrasting background; and
- Must appear separate and apart from, or be substantially more conspicuous than, descriptive or explanatory information.
More information on these requirements is available at 27 CFR 7.52–7.53.
What rules apply to the name and address used in the statement?
If beer is bottled at a single brewery location, the label must show the city and state where the product is bottled. The street address and zip code are optional. The name and address does not need to appear together on the label. The bottler’s name (or trade or operating name) and the city and State appearing on any label must be identical to the information approved on the brewer’s notice of the bottler. See 27 CFR 7.66(c) and (h).
Reminder: The city may not be abbreviated in the name and address statement.
The name and address of the bottler (or trade name of the bottler) may be preceded by an appropriate explanatory phrase, such as:
- “Brewed and Bottled/Packed by ______”
- “Brewed By ______” or
- “Bottled/Packed By ______”
If the product is bottled for a person other than the actual bottler, there may be stated in addition to the name and address of the bottler (but not in lieu of), the name and address of the other person, preceded by text such as “bottled for,” “distributed by,” or other similar appropriate explanatory phrase.
What if the product is being produced and bottled at multiple brewery locations under the same ownership?
Under 27 CFR 7.66(f), if two or more breweries are owned or operated by the same person, the place where bottled:
- May be shown as the only location on the label;
- May be included in a listing of the locations of breweries qualified under 27 CFR part 25, if the place of production is not given less emphasis than any of the other locations; or*
- Need not be shown if the brewer’s principal place of business is shown in lieu of any other location. The brewer’s principal place of business must be a location where bottling or packing operations take place.
If the location of two or more breweries is shown in lieu of the actual place of production, the actual location (address) where the malt beverage was produced must be indicated by printing, coding, or other markings on the label or container. If coding is used, the brewer must file, prior to use, a notice to TTB explaining the coding system. See 27 CFR 25.141(b)(2) and 25.142(b)(2).
Example for Brewers with Multiple Brewery Locations
- Hype Brewing Co. brews lager at all three of their breweries. Hype Brewing Co. may list the place of production separately for products brewed at each location, or use either of the name and address statement options below.
Are you operating as an Alternating Proprietorship?
An alternating proprietorship is an arrangement in which two or more brewers take turns using the physical premises of a brewery. TTB issued Industry Circular 2005-2 to provide guidance to brewers on how to qualify for and operate as an alternating proprietorship. Additional information can be found at Brewery Alternating Proprietorships.
Generally, the “host brewery” agrees to rent space and equipment to a “tenant brewer.” The tenant brewer is responsible for producing its beer, keeping appropriate brewery records, labeling the beer with its own name and address, obtaining the necessary COLAs, and paying tax at the appropriate rate upon removal of its beer for consumption or sale.
Name and address statements for malt beverages produced under alternating proprietorships must show the actual place where bottled. If applicable, the name and address statement for a tenant brewer’s product may appear as shown under the “Examples for Brewers with Multiple Brewery Locations” heading above.
What if the product is being contract bottled?
Contract bottling is an arrangement in which a brewer hires another company to bottle its product for them. See 27 CFR 7.66(g).
The contract bottler is responsible for:
- COLA submission
- Formula submission (as applicable)
- Keeping appropriate brewery records
- Paying taxes if the product is removed for consumption or sale
The label may state, in addition to (but not in lieu of) the name and address of the bottler, the name and address of the original brewer, immediately preceded by the words “brewed and bottled for” or “bottled for” or another similar appropriate phrase. Such statements must clearly indicate the relationship between the two persons (for example, contract brewing).
If the same brand of malt beverage is brewed and bottled by two or more breweries that are not under the same ownership, the label for each brewery may set forth all the locations where bottling takes place, as long as the label uses the actual location (and not the principal place of business) and as long as the nature of the arrangement is clearly set forth.
What if the product is being contract brewed and bottled?
Contract brewing is a business relationship in which one person, such as a wholesale or retail dealer or a brewer, pays a brewing company, the “contract brewer,” to produce and bottle beer for them.
As stated under TTB regulations, a brewer may not purchase taxpaid or tax determined beer from another brewer in bottles or cans that bear the name and address of the purchasing brewer. See 27 CFR 25.231(b).
The contract (producing) brewer is responsible for:
- Brewing product
- COLA submission
- Formula submission (as applicable)
- Keeping appropriate brewery records
- Paying taxes if the product is removed for consumption or sale
The name and address statement is based on a variety of factors. See acceptable scenarios for products that are contract brewed and bottled below.
- Scenario 1 (page 3) - Contract Brewing with Use of a Trade Name/Doing Business As (DBA)
- Scenario 2 (page 4) - Multiple Locations - Contractee and Contractor Location
- Scenario 3 (page 5) - Multiple Locations - Two Contract Brewing Locations (Same Label)
Page last reviewed: May 3, 2023