In a recent blog post from April 28th I shared about a wine label compliance discussion I had with Rob Mondavi. In that blog I posted (incorrectly!) that listing two sub AVAs of Napa Valley on a wine’s back label would not be considered in compliance per TTB regulations. My statement was based solely on the guiding TTB regulation for use of an AVA on a wine label. 27 CFR 4.25 e 3 (iii).
Many of you who have interacted with the TTB over the years specific to wine labels are aware that they are at times not black and white with the interpretation of their regulations. (A common source of frustration for our industry!)
So I did a little bit more digging directly with Marsha Heath from the TTB’s Industry Relations office in Washington DC. I explained my wine label AVA scenario to her, that Napa Valley would be listed on the wine’s front label and Atlas Peak and Howell Mountain would be listed in the descriptive text on the back label. Would this be acceptable to them?
Ms. Heath’s response was yes it would as long as those two sub AVAs of Napa Valley were:
1. Shown on the true back label for the wine
2. Listed in the “romance” language on the back label & not prominently otherwise
I asked for some sort of TTB regulation I could refer clients and students to as to why this AVA use would be acceptable to them. Her source: 27 CFR 4.38 (f)
This wine label regulation has the broad name of “additional information”. Sort of a catch all for the range of other statements or items that can show up on labels that are not specifically addressed in existing TTB label regulations.
As my AVA use on a wine back label scenario is very similar I had been hoping for something at least along the lines of the industry ruling from 1985 related to listing multiple varietals on a wine back label. It is “black and white” regulation references like this that I like to be able to direct clients and students to to help them understand what they can & can’t do on their wine labels.
Marsha Heath was very thorough and helpful during our call though, which I’ve come to appreciate & commonly expect with my frequent interactions with TTB staff.
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