This week’s blog post comes to you courtesy of a recent contact I had with a winery compliance colleague. Their request was for a post on a topic related to wine label requirements, and specifically what the TTB calls a wine’s “class and type”. This is a required item on all wine labels but many wineries were getting it wrong on the label files that they sent to my colleagues office.
One of the common services that offices like mine and others provide to winery clients is to submit their labels for TTB approval. (COLAs) As a part of that process we regularly need to request the wineries to make edits to their label files before they meet the requirements for submitting them to the TTB.
The issue my colleague was having: wineries that list “red blend” (as their class & type) on their wine’s front label. The winery’s intent is to use “red blend” instead of listing a single varietal name (pinot noir, cabernet sauvignon, etc) which is the other most commonly used class & type on wine labels. The problem with this is “red blend” is not on the TTB’s approved class & type list. A wine label that is submitted to the TTB for label approval that only lists “red blend” on it would come back marked “correction requested”, specific to the “red blend” class & type being insufficient.
What term is on the TTB’s approved class & type list?
Red wine. (along with white wine and rose wine by the way!)
As winery compliance consultants when we receive label files that list “red blend” or “white blend” or “Rose” we have to get back to the winery and request them to edit their wine label to instead list “red wine” or “red wine blend” or “white wine blend” or “white wine” or “rose wine” before he can go ahead and submit for TTB label approval. By the way if your wine is below 14% alcohol you can also list “red table wine” or “white table wine” or “rose table wine” on the label as the class and type & you would NOT need to list an alcohol percent.
While we’re on the topic of wine blends and their labels- there are two options that wineries have if they desire to elaborate a bit further about the varietals that make up their “red wine blend”. (or white wine or rose wine)
Option 1. They may list the varietals in the blend on the wine’s front (brand) label. They list the varietals along with their percentage in descending order and the percentages must total to 100%.
Option 2. A winery can list “red wine blend” (or white wine or rose wine) on their front (brand) label and then elaborate on that further by listing the varietals in the wine’s blend in the back label text. If a winery chooses this option they must list in descending order any varietals in the blend that account for 5% or more. There is no requirement to list their percentages with this option. This option fits if your wine blend has several varietals in it and they won’t all fit on your front label along with their percentages but you’d like to be able to share all those details with your wine drinking public.