I placed calls to two sources at the TTB to get an answer. The most clear and helpful answer came from Mari Kirrane, the TTB wine specialist who is on the receiving end of a lot of my random TTB questions. The answer? Yes- any wine that is filled into 5 gallon kegs (or bottles, bags, jugs or other containers for that matter which will eventually be given to a consumer) must have a label approval for it.
I think what had initially thrown me off was the different concept of the wine not being “bottled” in the traditional sense, but instead being filled into a much larger container, in this case a stainless steel keg. So a line of these kegs isn’t being loaded onto a conveyor belt on a bottling line. Instead the wine is filled into the kegs one by one in a more hands on process.
But nonetheless though it may not be a traditional bottling activity it is the finished product being packaged up to go out to the consumer, so after the kegs are filled with wine a label must also be attached. This can mean that the labels for your kegs are done by a printing business or you also have a lower cost option of just printing them out via your own computer and use tape to apply them securely onto the kegs.
Next I had to request some changes to my client’s label. The first change was of course for the capacity of the larger container. You actually can’t list “5 Gallons” on a wine label. In this case, the TTB only accepts capacity amounts in whole liter statements. For the required net contents on a 5 gallon keg label it would need to state “19L”.
The second required label item change is related to the name & address statement. This statement we are commonly used to viewing as something like, “produced and bottled by…….”. The TTB requirements state that for wines that are filled into containers that are larger than 4 liters “bottled” changes to “packed”. So my client’s label needed to state, “produced and packed by….”.
The edits were made to the wine label and the label approval was submitted.
Chalk down something else new learned in the world of TTB compliance.