Each year the TTB (Alcohol & Tobacco Tax & Trade Bureau, the federal agency which regulates the alcoholic beverage industry) receives more and more applications for label approvals on alcoholic beverages that are sold in this country. A statistic from 2008 had the total of applications received at over 133,000, and somewhere around 85% of those applications were for wine labels. In perhaps an effort to reduce this volume of applications, the TTB has made an effort over recent years to make sure the wine industry in particular is aware that in many instances a new label approval is not necessary from one bottling year to the next.
So just what are some of these examples of changes you may make to your wine labels from one year to the next that do NOT require a new approval? There are a range of them, starting with items that can be deleted, moving onto items that can be changed, and finishing with items that can be added, deleted or changed.
For starters an allowable deletion would be any item that is a non-mandatory one. Wine labels are required to have a list of specific items on them, so deleting any other item on your label which is not a mandatory one is allowed. For example, there are several items that commonly appear on wine labels, vintage, varietal and appellation among them which are NOT required to be there. So for one year a wine may state 2009 on the label and then the next year that could be deleted and no new label approval would be required for the next bottling of that wine. This bodes well for wineries who like to keep things simple and generally do not make many changes to their labels from year to year.
Some of the items the TTB allows changes to without a new label approval include changing the alcohol percentage, and the tradename that is used in the bottler’s statement. For the alcohol percentage this is an allowable change as long as the alcohol is still in the same tax class as the previous approval for that wine. The tradename is the item that appears in the “bottled by XYZ Vineyards” which is a required item for all wine labels. The tradename in my example here is XYZ Vineyards. So XYZ Vineyards could be changed to another trade name on your label and no new label approval would be necessary.
Lastly, there are several items that can be either added, changed or deleted and no new COLA is required. These include UPC barcodes, website addresses and your bonded winery number. Back label text can also be deleted as well from one year to the next on a wine label and as long as no new text is added to replace it no new approval necessary.
Wineries can definetely save themselves (And the TTB) some time if they are aware of this list of allowable changes to their labels and pull it back out each time they have a wine coming back up for its next bottling. The list can be found by going to the TTB’s website and accessing their “TTB Wine Seminar handout packet” of which it is part of. Their website is: http://ttb.gov/wine