The name and address statement provides the name and address of the importer or the bottler of the distilled spirits, as applicable. Where distilled spirits are bottled by or for the distiller or processor (rectifier) of the spirits, the label may instead state the phrase “distilled by” (or whatever phrase applies to the processing or rectifying operation), followed by the name (or trade name) under which the particular spirits were distilled or rectified, or any trade name shown on the basic permit. See 27 CFR 5.66 for more details, including special rules for distilled spirits labeled as being “bottled in bond” and the use of multiple locations on labels
In this example,”Bottled By: ABC Distillery Frederick, MD” is bottlers name and address statement.
For imported distilled spirits, the name and address generally consists of the name of the importer and the address of the importer’s principal place of business, as shown on the basic permit. It must be preceded by the phrase “Imported by,” or a similar phrase such as “Sole Agent” or “Sole U.S Agent.” See 27 CFR 5.68 for more details.
In this example, "IMPORTED BY: 12345 IMPORTS MIAMI, FL" is the importers name and address statement.
For imported distilled spirits that are bottled, packed or filled after importation, the name and address of the bottler, packer or filler must appear on the label preceded by an appropriate explanatory phrase such as “Bottled by.” However, if the spirits are bottled by or for the person responsible for the importation, the name and address of the importer may appear instead, along with an appropriate phrase such as “imported by and bottled in the United States for” or “imported and bottled by.”
Where should the name and address statement be placed on the product?
It may appear on any label on the container.
What are the formatting requirements for the required name and address statement?
Type size:
- Minimum 2 mm for containers larger than 200 mL;
- Minimum 1 mm for containers of 200 mL or less.
Note: The name and address statement is not required to be in all capital letters; however the minimum type size applies to each numeral or letter in the statement, including both upper-case and lower-case letters.
Legibility:
- Must generally appear parallel to the base of the container.
- 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.
See 27 CFR 5.52-5.53 for additional legibility and formatting requirements.
What rules apply to the name used in the statement?
A name (or trade name) of any permitee appearing on any label must be identical to the name appearing on the basic permit.
What rules apply to the address used in the statement?
The address of a bottler or other distilled spirit premises shown on the label is the place where the operation occurred. This means the post office address shown on the basic permit or other qualifying document of the premises at which the operations took place. The street address and zip code may be omitted. The city and state are required. The label may state the address of the proprietor's principal place of business in lieu of the place where the bottling, distilling or rectification operation occurred, if the address where the operation occurred is indicated by printing, coding, or other markings, on the label or on the bottle.
In the case of an importer, the address shown on the label is the city and state of the principal place of business of the importer (or other persons responsible for importation) in the United States, as shown on the basic permit.
What rules apply when one importer borrows another importer’s COLA?
In general, an importer may use a COLA issued to another importer if: (1) The importer to which the COLA was issued has authorized such use, (2) each bottle or individual container bears the name (or trade name) and address of the importer to which the COLA was issued, and (3) the importer to which the COLA was issued maintains records of the companies it has authorized to use its certificate.
As of December 22, 2022: this document was updated for purposes of T.D. TTB-176, Modernization of the Labeling and Advertising Regulations for Distilled Spirits and Malt Beverages.