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General Labeling Requirements

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The TTB labeling requirements are codified at Title 27 C.F.R. part 4 for wine, part 5 for distilled spirits, and part 7 for malt beverages. Use of words of geographic significance on wine labels is additionally covered in part 12. The alcohol beverage warning statement is covered in part 16.

The general labeling requirements bear similarities with those of food. For example, a wine label must include the brand name,81 the class of wine,82 name and address of where the wine was bottled or packed preceded by words “bottled by” or “packed by” for American wine or “imported by” or similar term for imported wine,83 the net contents,84 and a declaration of sulfites if a sulfur dioxide or a sulfiting agent is detected at a level of ten or more parts per million.85

However, there are a number of distinctions from food labeling. For example, a wine label must include the alcohol content and there are a number of considerations about the appellation of origin and related terms. The alcohol content is declared as “Alcohol ____% by Vol.” or wineries can use “Table Wine” or “Light Wine” if the alcohol content is 7 percent to 14 percent.86 The class of wine includes terms such as “grape,” “table,” “light,” “white,” “red,” “pink,” “amber,” “rose,” or “dessert” followed by the word “wine.”87 An appellation of origin, such as “Napa Valley” or “Chilean,” is mandatory in certain circumstance where the type, vintage date, or the term “estate” is used.88 On blends consisting of American and foreign wines, if any reference is made to the presence of foreign wine, the exact percentage by volume must be declared.

Food Regulation

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