Wednesday, July 24, 2013

Important Changes to Wine Label Regulations

Dear FWWS Member

Many of you may already be aware of a recent TTB circular regarding liberalization of label approval guidelines.  However, based on conversations with TTB staff and member wineries, we believe this TTB circular is important enough, and was missed by enough people, to be worth re-visiting.  It’s not every day that a government agency takes action to significantly reduce the reach of regulatory requirements and this effort is both commendable and worth highlighting.

Here are just a few of many changes to labels that now are allowed without submittal of a new Certificate of Label Approval (COLA) application:

1)       Changing the alcohol content across the 14% alcohol tax class threshold (particularly important for those of us who haven’t yet labeled our reds from the cool, low alcohol 2011 vintage)
2)       Changing font styles, background colors, label shape, and label media (for example from adhesive backed to screen printed on the bottle)
3)       Deleting any non-mandatory information.
4)       Adding, changing or deleting web site addresses, UPC symbols or QR codes (Note: Please read our upcoming blog posting on TTB advertising requirements as regards QR codes and website references)
has a nice graphic showing some changes to sample labels that are now allowable.  There is also a concise table that will further clarify label requirements.

The full text of TTB circular 2012-2, together with its embedded links can be found at this link:
This is good news! We urge all of you to read the full TTB industry circular or, at the very least, to take five minutes to read the overview of changes at the first link above.  The first link has a printer friendly version available and is concise enough to use as a quick reference guide.

These changes are material, substantial, and positive, and not only increase stylistic flexibility for wineries but will also significantly reduce the need to re-submit COLA applications for existing wines.

Your FWWS Board

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