Category Archives: Wine Labels

AVAs on Wine Labels: Continued
Posted on 2015-03-31 by Ann Reynolds

Last week I wrote about the conjunctive labeling laws on the books here in California – and specifically the requirement of placing the parent AVA, Napa Valley next to any sub-AVA of it that is listed on any labels placed on a bottle of wine.

I realized this topic ties directly in with a TTB requirement related to how wineries are tracking those loads of sub Napa Valley AVA grapes. This topic is an issue I have seen often at wineries over the years, and is related to their weigh tags, or more formally known as weighmaster certificates.

Weighmaster certificates are a legally regulated document which track the purchase/sale of a load of wine grapes. (in this example) They are required to have a specific set of text & fields on them, however an appellation field is not one of them.  Here is where the TTB rub comes in.

The TTB sees a weigh tag documenting a load of grapes as a “source document” or in other words think of them as birth certificates for your wines. The details that you fill in on a weigh tag tie directly in with what you eventually will or will not qualify to list on the wine label for the wine those grapes become a part of.

Here is an example of what I’ve seen commonly happening on weigh tags. A load of grapes from a sub AVA of Napa Valley comes into a winery. The winery does have an appellation field on their weighmaster certificate template. (Score one point for their compliance!)  However when they write up the weigh tag for that load of grapes they fill in the appellation field with “Napa Valley” when they need to list the sub AVA instead. This will mean that come label design time for the wine those grapes are made into it would NOT qualify to list the sub AVA on its label – because it was not documented on the “source document” or weigh tag.

If wineries would first make sure to include an appellation field on their weighmaster certificate template and then next ALWAYS be as narrow as possible in the AVA they list on all their weigh tags this will provide them the widest options come label design time & cover them to any TTB scrutiny.





What do the proposed Paso Robles AVAs mean for your weigh tags right now?
Posted on 2013-09-26 by Ann Reynolds

AVA

I see that 11 new petitions have recently been submitted to the TTB for new AVAs all within the current Paso Robles AVA. For one, that’s a lot of slicing and dicing all at once! And of course there has already been plenty of history to the quest to create several more sub-AVAs within the sizeable piece of land that the parent AVA Paso Robles already is. (5th largest in California)

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5 Gallon Kegs, Label Approvals and You.
Posted on 2013-04-12 by Ann Reynolds

5 gallon kegs have become a popular way for wineries to get their product out into the marketplace, specifically the by-the-glass marketplace. I had a client contact me recently for assistance with a new label approval (COLA) for his upcoming bottling. I’ve filed these for him in the past but this year was the first time he’d decided to try out the 5 gallon keg route. He asked me if a label approval was required for them, and I honestly didn’t have an answer for him right away.

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TTB Label Approval Search Advice From Eliot Ness
Posted on 2012-06-28 by Ann Reynolds

The TTB’s website really does have a lot of good information. (If you know where to look) I myself can vouch for this firsthand as I’ve been viewing it as part of my profession since 1998. It has come a long way since then! Now they are going back to their roots by including a section titled, “Eliot Knows” which is basically a version of their FAQs page.

Eliot’s latest information for the curious wine regulation searcher is about one of the TTB’s sites, the Public COLA Registry.

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Teaching An Old Wine a New AVA.
Posted on 2012-04-11 by Ann Reynolds

A recent discussion came up on Facebook around the use of newly created AVAs (American Viticultural Areas) on wine labels made from vintages pre the AVA’s existence. The discussion was around the recently created AVA of Coombsville in eastern Napa. The question that came up was would that be allowable under the TTB’s labeling regulations? i.e. If you are about to bottle a 2009 wine and wanted to put Coombsville (which became an AVA in December 2011) as an AVA on the label could you do this?

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Does Your Wine Have an Outdated Identity?
Posted on 2012-04-04 by Ann Reynolds

Did you know that all wines have a standard of identity? All US wines that is, and this is in relation to how the TTB (www.ttb.gov/wine) defines them. A required item for any wine label is what the TTB refers to as a “class & type”. In most of our cases the class we are speaking of is the “grape wine” class. (Some of the others include citrus, fruit and sparkling just FYI) Then moving into the “class” part of it the list of options there used to include 17 designations of European origin. An agreement was signed between the US and the EU in 2006 which essentially removed those 17 designations for use on US wine labels unless you’d grandfathered their use in via earlier labels.

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For Whom The Label Approval Responsibility Tolls.
Posted on 2011-12-20 by Ann Reynolds

Back on the ever popular topic of wine labels, I’ve got a question for all of you involved in the label approval part of the process. Say a wine is made at winery A but then shipped to winery B to be bottled. Which winery is responsible for obtaining the TTB label approval for it?

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How to Create the Perfect Blend When Designing Your Wine Labels.
Posted on 2011-12-01 by Ann Reynolds

The practice of winemaking is often referred to as an art or a craft. The process of creating a label is a very intricate one as well. It is intricate not only because of the TTB regulations that surround them but also because of the many parties that are involved in their design. From winery to winery that list of involved players does vary which has a direct correlation with how efficiently (Or not!) labels are planned for.

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OK Wineries………….Everybody Concentrate!
Posted on 2011-11-20 by Ann Reynolds

This is a cautionary post for all the wineries that as a result of the low sugar levels in their fruit this year due to the lack of a summer decided to boost the sugar level of their batches of juice and must by adding grape concentrate. Beware that come bottling time for any of those finished wines that had concentrate added to them they will not be eligible for “Estate Bottled” on their label.

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Wine Labels: The Big Picture of Appellations.
Posted on 2011-07-25 by Ann Reynolds

Appellations: The Location, location, location of Wine.

Just like the phrase from the real estate world, wine is often all about location, location, location. In the case of wine the terminology used is appellation. A wine’s appellation is the details on its bloodlines or where the grapes used to make the wine were grown. We are fairly accustomed to viewing an appellation on most wine labels though their use on a wine label is not a required item, but if one is used the wine blend must meet specific percentage requirements. In this case I wanted to show an example of the largest yet rarely seen appellation available to US wines, the American appellation.

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