TTB Product Labeling Requirements

The Department of Treasury, Alcohol and Tobacco Tax and Trade Bureau, regulates the content and registration of wine and liquor labels and products imported into the U.S. Such products must comply with the Federal Alcohol Administration Act, (“AAA”) 27 USC 201 et seq., the Alcoholic Beverage Labeling Act of 1988, 27 USC 213 et seq., and Internal Revenue Code, 26 USC Chapter 51.

Wine labels must include the following mandatory information:

1. An appropriate brand name;
2. The correct class, type, or other designation;
3. Alcohol content including specific location, format, size, and information;
4. Declarations of the percentage of foreign wine;
5. Name & address of the importer & the bottler or packer if packed after importation
6. Net contents in proper format, location, and size;
7. Food coloring, as required;
8. Declaration of sulfites in proper format;
9. Country of Origin;
10. Health Warning Statement, following specific text, format, location, and text size;
11. Vintage date; based upon very strict guidelines;
12. Declaration of saccharin, if added

In addition, their are specific guidelines relating to the following issues that must be followed:

1. Vintage;
2. Appellation of origin;
3. Varietal designation;
4. Estate bottling information;
5. Use of “Organic” Ingredients:

It is critical to ensure your product labels comply with U.S. requirements.

Certificate of Label Approval

A Certificate of Label Approval authorizes the certificate holder to bottle and remove or import alcoholic beverages that bear labels identical to those shown on the COLA from Customs custody. No imported wine can be released by Customs unless the Customs officer receives a copy of an approved COLA. All wine sold in the US must be labeled in conformity with the information on the COLA. COLA’s are issued by the appropriate TTB officer.

At times, TTB may require evidence of compliance with FDA or USDA requirements, depending upon the ingredients used to make the wine or statements made on the wine label (e.g. "organic" claims).

Certificates of origin and of process

Wine imports must also be accompanied by a certificate of origin issued by a foreign government. Wine importers also need to comply with certification requirements under the Miscellaneous Trade and Technical Corrections Act of 2004 to ensure that the practices and procedures used to produce the imported wine constitute proper cellar treatment. This certification can include a statement from the producing country’s government or government-approved entity having oversight and control of enological practices.

FDAImports.com consultants and affiliated attorneys regularly assist domestic wine importers and foreign wine processors in complying with TTB, FDA, USDA, and Customs requirements.