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Are the AVAs on the Elouan back label OK? (from a TTB viewpoint)

I get Lew Perdue's daily Wine News fetch email which helps keep me in the loop on the stories in the wine business world and often inspire my blogs/videos. A story in one of those headlines caught my eye this week- since it covered a topic I am waist deep in on a steady basis. Wine labels! The topic of this weeks story is about a Pinot Noir label under the brand Elouan, the label is an Oregon Pinot Noir that was bottled by Elouan in Rutherford, CA.

The more specific reason this caught my eye was three years ago in June 2015 I wrote a blog post on the very same topic (of controversy) with this current wine label. That is, listing AVAs on a wine's back label.  At that time in 2015 I reached out directly to a veteran TTB staff member, Marsha Heath to determine what would or would not be allowed specific to listing AVAs on a wine's back label. 

After refreshing my memory about what Ms Heath's responses were I took a closer look at the Elouan label to see how it stood up to her guidance.

See my video on that here