The TTB has just released an update announcing more surprising changes to their COLAs online platform. If COLAs online has no meaning for you it is the electronic label approval platform through which the majority of applications are filed for all alcoholic beverages. The amount of applications submitted for wine just happens to make up the largest percentage of the overall volume submitted.
The following items will no longer have fields on the label approval application:
Alcohol content (!)
They are also making changes to the appellation field which will now be accommodated by a two step process involving two drop down menus. Applicants will first select the type of appellation be that AVA, county or state, multi county, american or foreign and then further clarify the actual AVA, county, multi county, or state name at the next drop down menu.
I myself am extremely surprised by the elimination of two of the required wine label items, the alcohol content and net contents. Why the TTB has decided in its regulating wisdom to remove those fields from a label approval application is a mystery to me.
Simply by the fact alone that alcohol content and net contents are part of the list of 8 required items for any wine label. For those of you who would like to view the full list of these mandatory items in complete TTB legal lingo here’s a link.
By the way wineries- these changes don’t mean that you no longer need to list an alcohol content or 750 ml on your wine labels! Don’t be confused by these application changes. All wine labels are still required to list the mandatory items listed in section 4.32 of the federal regulations. You just won’t be required to fill them in as part of submitting a label approval application.
Now on the other hand of this update to wine label approvals is the fact that a vintage, varietal, or appellation are actually not required items for a wine label. It is only when a winery chooses to list them on their labels that they are then required to meet the minimum percentage requirements behind listing any of those items. The majority of wine labels do list one or more of these three items, as they are a significant part of a winery’s marketing as well as being how many consumers base their wine choices.
Here is a link to the TTB’s update summary of these changes that will go into effect later this month.