Wine Labels Won't Change

TTB approval process gets simpler, but consumer-facing information will remain the same

by Jane Firstenfeld
wine winery labels COLS TTB
Under proposed changes, wineries would not be required enter net content, alcohol content or vintage when applying for a Certificate of Label Approval (COLA) from the from the Alcohol and Tobacco Tax and Trade Bureau, although the labels themselves will still contain that information.
Washington, D.C.—Label design is perhaps the most aesthetically pleasing aspect of wine packaging, but legal compliance for label approvals is not always well understood by wineries that market in the United States. The tiniest boutique wineries don’t have the resources to employ full-time compliance experts, as larger producers do. Small to mid-sized wineries frequently retain specialized compliance consultants to win approval for their labels.

Recently, the  Alcohol and Tobacco Tax and Trade Bureau (TTB) announced changes to the COLA (Certificate of Label Approval) procedure, the first essential step in the process.

Experienced compliance experts Ann Reynolds of Wine Compliance Alliance in Napa, Calif., and Liz Holtzclaw of Holtzclaw Compliance in Modesto, Calif., emphasized that the COLA online procedure has been simplified by eliminating several requirements, but what’s on the finished label remains the same.

The vast majority of COLAs are issued online. Reynolds and Holtzclaw agreed that the redesigned form should help speed the process for both applying wineries and the TTB.

The following items will no longer have fields on the label-approval application:
• Alcohol content
• Net contents
• Vintage

The procedure for claiming an appellation also has changed and is accommodated by a two-step process using drop-down menus. Applicants must first select the appellation (AVA, county or state, multi-county, American or foreign) then further clarify the actual appellation on the next drop-down menu item.

Holtzclaw noted that some wineries still file applications on paper, rather than online, which not surprisingly lengthens the process. Paper application forms have similarly been altered.

She stressed that although the application has been simplified, labels themselves must include all the existing requirements. Printed labels still must list alcohol content and net contents in TTB-approved sizes (e.g., 175ml, 350ml, 750ml up to 3 liters).

Special cases

She also indicated that wineries joining the canned-wine movement would be wise to bundle the cans in multi-packs or shrink-wrap them to meet requirements for approved sizes. She added that should cans, which may include odd serving sizes, be broken down on store shelves for individual sale, they may face confiscation.

Holtzclaw also previewed a potential new TTB change that would eliminate the certificate of exemption for wines made with grapes transported from out-of-state and sold only within the state where they are vinified.

Initiated after the end of Prohibition, the current law was written because grapes were transported in unrefrigerated trucks or freight cars and often deteriorated prior to vinification. With modern refrigeration, she said, that’s no longer a problem. “I think the current law is pure protectionism,” she said.

View the proposed rule change here. Public comments must be submitted by Dec. 7, 2016.

Posted on 10.07.2016 - 10:09:22 PST
No, that is not what is happening. The alcohol content will still be on labels, and so will optional vintage if the producer chooses and the wine qualifies for one. It is the application form itself that is changing.
Liz Holtzclaw

Posted on 10.07.2016 - 08:05:13 PST
Am I understanding this right that no longer will the vintages of the wine or alcohol content will be on wine labels???