Wine Labeling: Overview of Labeling Requirements for Imported Wines

Before importing wines into the United States, importers should understand what information must, may, and may not appear on a wine label, and whether you need to apply to TTB for approval before using the label. Requirements differ based on whether the wine contains 7 percent or more alcohol by volume, or less than 7 percent alcohol by volume.

7 percent or more | Less than 7 percent

7 percent or more

How must imported wines that contain 7 percent or more alcohol by volume be labeled?

The Federal Alcohol Administration Act (FAA Act) imposes certain packaging and labeling requirements on wines (containing at least 7 percent alcohol by volume) that are imported in containers used for the sale of wine at retail.  Generally, these wines must be labeled with the following information required by 27 CFR 4.32 and 4.34, as well as the health warning statement required by the Alcoholic Beverage Labeling Act of 1988 and 27 CFR part 16:

Required information on the brand label:

Required information on any label:

 

Please refer to each mandatory information topic page for full requirements.

Wine labels may also contain optional information, such as a vintage date or organic claims. In addition, some labeling practices are prohibited. Please refer to the optional information topic pages and 27 CFR part 4 for details.

In addition to the label information listed above, containers of all imported wines are required to be marked, branded, and labeled (for example, with a Country of Origin statement) in compliance with U.S. Customs and Border Protection (CBP) regulations found in 19 CFR part 11, part 12, and part 134.

Do labels for containers of imported wine that contains 7 percent or more alcohol by volume need to be submitted to TTB for review prior to importation?

Yes. The FAA Act prohibits an importer from removing from customs custody for consumption (if the removal is for sale or any other commercial purpose) containers of wine that contains 7 percent or more alcohol by volume unless the importer has in his or her possession a Certificate of Label Approval, commonly referred to as a COLA, issued by TTB covering that wine.

The purpose of a COLA is to ensure that the wine is labeled in compliance with TTB regulations.

Once you have a COLA, you may make certain allowable revisions to the approved label without needing to submit the revised label to TTB for another review.

For additional details about these certificates, including how to apply to TTB to receive them, see the COLAs Online Frequently Asked Questions.

Do I need a COLA for wine that is imported in bulk containers?

No.  Natural wine may be imported without payment of tax in bulk for transfer to a winery.  Any wine may be imported and taxpaid in a bulk container that is not made for use for the sale of wine at retail.  Because these wines are not in containers used for the sale of wine at retail, the wine is not required to be covered by a COLA at the time of importation.   Instead, the domestic winery or taxpaid wine bottling house must obtain a COLA prior to bottling the imported wine for sale in interstate commerce.

Is any additional approval or documentation required to import bottled wine containing 7 percent or more alcohol by volume into the United States?

Please refer to Importing Bottled Alcohol Beverages Into the United States for information on importers’ permits, taxes and duties, natural wine certification, and certificate of age and origin requirements, among other important topics.

Additionally, some wines containing 7 percent or more alcohol by volume (such as wines made with added flavors, aperitifs, and sakés) require formula approval.  Please read our formulation page for more information.  Please note that some products that require formula approval also require laboratory sample analysis.  See the Which Alcohol Beverages Require Formula Approval? tool to determine whether you need to apply for formula approval. If formula approval is required, it must be obtained prior to applying for a COLA.

Less than 7 percent

How must imported wines that contain less than 7 percent alcohol by volume be labeled?

The FAA Act does 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, other labeling requirements that apply to those wines.

  1. Food and Drug Administration 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

  1. Customs Labeling Requirements. Containers of all imported wines are required to be marked, branded, and labeled (for example, with a country of origin statement) in compliance with U.S. Customs and Border Protection regulations found in 19 CFR part 11, part 12, and part 134.

  2. 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.  (Specific requirements are found in 27 CFR part 16.)

    See Health Warning Statement for additional guidance on the wording, formatting, and placement requirements.

Do I need to get a TTB COLA or FDA pre-approval of my labels for wine that contains 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 wines that contain 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.

Is any additional approval or documentation required to import my bottled wine that contains less than 7 percent alcohol by volume into the United States?

Please refer to Importing Bottled Alcohol Beverages Into the United States for general information on importers’ permits, taxes and duties, natural wine certification, and certificate of age and origin requirements, among other important topics.  Some of these requirements apply only to wines under the FAA Act, and will not be relevant to you if your business is restricted to importing only wines that contain less than 7 percent alcohol by volume.  Note that imported wines that contain less than 7 percent alcohol by volume are not subject to TTB’s formula approval requirements.

 

 

Page last reviewed: March 1, 2021
Page last updated: March 1, 2021 
Maintained by: Office of Communications