Prior to bottling wine for sale in the United States, producers and bottlers should understand what information must, may, and may not appear on a wine label, and whether they need to apply to TTB for approval before using the label. Requirements differ based on whether the wine contains less than 7 percent alcohol by volume, or 7 percent or more alcohol by volume.
How must wines that contain less than 7 percent alcohol by volume be labeled?
The Federal Alcohol Administration (FAA) Act labeling provisions do not apply to wines that contain less than 7 percent alcohol by volume. Therefore, those wines are not subject to the labeling requirements found in 27 CFR part 4. There are, however, some mandatory labeling requirements that apply to wines that contain less than 7 percent alcohol by volume. These requirements are found in 27 CFR parts 16 and 24.
Additionally, wines with less than 7 percent alcohol by volume must comply with applicable U.S. Food and Drug Administration (FDA) food labeling and packaging requirements, including ingredient, nutrition, and allergen labeling requirements.
- Labeling Requirements under 27 CFR part 24
Under the Internal Revenue Code provisions in 27 CFR 24.257(a), proprietors of wine premises must label each bottle or other container of beverage wine prior to removal for consumption or sale with the following information:
- Name and address of the wine premises where bottled or packed;
- Brand name (if different from the name of the premises where bottled and packed);
- Alcohol content, as percent by volume or in a format described in 27 CFR 4.36 and 4.38(b)(3);
- Net contents of the container; and
- Designation of the kind of wine: The designation must include enough information (when viewed with the alcohol content statement) to identify the tax class of the wine and to adequately disclose the nature and composition of the wine. The wine must be identified by the term “wine” (or a word that signifies a type of wine, such as “cider,” “perry,” or “mead,” as applicable). If the wine contains more than 0.392 gram of carbon dioxide per 100 mL, the word “sparkling” or “carbonated,” as applicable, must be included in the designation.
Containers larger than 4 liters, or cases used to remove smaller containers, must be marked with the information required in 27 CFR 24.259.
- Health Warning Statement
Alcohol beverages bottled or imported for sale or distribution in the United States, including wines containing at least 0.5 percent alcohol by volume and intended for human consumption, must bear the health warning statement required by the Alcoholic Beverage Labeling Act. (27 CFR part 16).
See Health Warning Statement for additional guidance on wording, formatting, and placement requirements. - FDA Labeling Requirements
Wine that contains less than 7 percent alcohol by volume is subject to the food labeling regulations issued by the U.S. Food and Drug Administration (FDA) under the Federal Food, Drug, and Cosmetic Act (FD&C Act). Labels for such wine must comply with applicable FDA food labeling requirements, including ingredient labeling, nutrition labeling, and allergen labeling requirements.
Questions concerning the labeling of food products may be directed to:
Food Labeling and Standards Staff (HFS-820)
Office of Nutrition, Labeling, and Dietary Supplements, Center for Food Safety and Applied Nutrition
Food and Drug Administration
5100 Paint Branch Parkway
College Park, MD 20740-3835
Telephone: (240) 402-2371
Do I need to get a TTB COLA or FDA pre-approval of my labels for wine with less than 7 percent alcohol by volume?
There are no Federal pre-approval requirements for the labels of wines that contain less than 7 percent alcohol by volume. The TTB COLA requirement is found in the FAA Act, which does not apply to wine that contains less than 7 percent alcohol by volume, and FDA does not pre-approve labels for food products.
Some states may require label approval for alcohol beverages before they may sold in that state. You may use our Alcohol Beverage Authorities in United States, Canada, and Puerto Rico listing to find contacts in each state. TTB does not have authority to issue a COLA for wine that contains less than 7 percent alcohol by volume. If a state agency asks for a TTB COLA for such a wine, please direct them to this guidance page.
Do the TTB formula approval requirements apply to wine with less than 7 percent alcohol by volume?
The formula requirements for domestic wines, described in 27 CFR 24.80, 24.81, 24.196, 24.201, and 24.211, apply regardless of whether the alcohol content of the wine is below, above, or at 7 percent alcohol by volume. See TTB’s Which Alcohol Beverages Require Formula Approval? to determine whether your wine needs formula approval.