Often, the essence of a brand’s identity is expressed in the wine’s label. A great deal of thought usually goes into creating a visually memorable label. However, there are several key label approval requirements for wines destined for the US market. Understanding these requirements makes the job of getting your labels approved easier and quicker. Perhaps even more importantly it will demonstrate to potential importer and distributor partners that you under- stand the US compliance environment and that you are ready and committed to do business in this complex yet potentially rewarding market.
One very important requirement for a wine to be imported into the United States is that it must have a label that has been approved by the Tax and Trade Bureau (TTB) of the Department of the Treasury. Like most government processes, if the rules and procedures are followed precisely, the label approval process is straight for ward and can even be fairly quick. If not, the process will involve multiple extra steps and the label may never get approved. This fact sheet explains the primary things to do and not to do when seeking a Certificate of Label Approval (COLA) from the TTB for importation.
For a winery seeking importation into the U.S., it is usually nec- essary to send samples to potential importers or to reviewers, competitions, and trade shows that will give your wine exposure. Without a label, however, this would be illegal—and you can’t get a Certificate of Label Approval (COLA) until after you have an im- porter. The TTB’s solution is the COLA waiver, which grants per- mission to ship wines to specific people or companies before a commercial label has been approved.
Once the COLA waiver is received, the samples can be shipped. Each bottle must be labeled with the phrase “For Sample Purposes Only—Not For Sale,” along with the Government Warning and the sulfite declaration, and the appropriate taxes must be paid. More
details are available here at the TTB website.
Exhibitors at Vinexpo America who take advantage of the services provided by W&S Logistics will have the COLA waiver completed as part of their service. It is strongly advised that exhibitors use W&S Logistics to ship wines destined for Vinexpo America as they are extremely proficient in all aspects of getting your wines to the event.
In general, the placement of the information is not important, but all the mandatory information must be present somewhere.
For your first time working with the TTB, it might be a good idea to put all the mandatory information on a back label. You can still duplicate some of
it on the front label, too, but this way, nothing will be missing. The back label— containing the brand name, class, and type—will be the one designated as the brand label in the COLA application.
USDA organic requirements are specific and strict when it comes to wine labels using the term “organic” or especially “organic wine” in the United States. Imported wines that are certified organic in their home countries should work with their certifying body to get the documentation they will need to submit to the TTB as proof of their organic status. The exact terms used on a wine label vary de- pending on the extent of organic compliance, such as:
Inaccurate information and optional terms that the wine does not qualify for are not allowed on labels. In addition, U.S. labeling laws and TTB policies forbid, or at least frown on, certain other items on wine labels, including the following:
Episode 1: U.S. Wine Market Structure: Vinexpo video tutorial on label compliance, beginning after minute 27.
TTB Wine Labeling Resource Documents: Webpage with list of useful links.
TTB What You Should Know About Grape Wine Labels: 2-page brochure with annotated example of wine label.
TTB Beverage Alcohol Manual (BAM): The Beverage Alcohol Manual (BAM) is a 60-page publication from the TTB (U.S. Tax & Trade Bureau) that summarizes the labeling requirements for wine sold in the United States, with examples of different label formats.
“Sample Wine Labels” (from the BAM), complete with images.
TTB Organic Wine Labeling Guide: 7-page document with examples of accept- able and unacceptable labels.
TTB Information Sheet on Organic Labeling Policies: 1-page webpage summa- rizing the labeling and the allowable percentage statements for wines contain- ing organic and non-organic ingredients.
List of Allowable Changes to Approved Labels: As the name implies, a list of allowable changes that can be made to already approved labels.
For anyone wanting to read more in-depth books on success strategies for en- tering the US market or see a list of current wine & spirits industry newsletters where you can access US market data, please consult the Resources Directory found here.