For Whom The Label Approval Responsibility Tolls.
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?
If you answered winery B you win the prize! The always correct answer to the question- "who is responsible for obtaining a label approval when it is required?" is the BOTTLING winery. Always. Each and every time.
But what about when a wine is bottled as shiners (industry lingo for without labels) and then is sent to another winery to have the labels put on when they are ready? Per TTB regulations label approval responsibility always comes back to the bottling winery for all wines bottled on their site.
This example I list above of winery A making the wine at their site and then shipping it to winery B for bottling has some other impacts related to the label. First, the wine would not qualify to use the term "produced" in its bottling statement.
The bottling statement is the required statement which most commonly appears on the back label of a wine and generally goes something like, "Produced and bottled by XYZ winery, somewhere, CA" . The term "produced" in this statement has a specific definition the wine must qualify for which is tied directly to where the majority of it (at least 75%) was fermented.
The second area of impact is what the TTB refers to as the trade name in that same bottling statement. So in my example above the trade name is XYZ winery. For any winery that bottles wine they are required to maintain a list of the trade names on their permit for all the wines they will bottle, regardless of whose wines they are.
What that means in my example scenario above is that winery A that made & sent the wine to winery B to bottle it would then need to provide the necessary materials to winery B to add their trade name from the label of the wine to be bottled to their (winery B's) TTB permit. If this step in the process is not taken care of the label approval will come back rejected from the TTB because of this issue.
Just another friendly reminder for any and all of you "holding down the label approval fort".