Making Sense of Wine Labeling

Now that I am officially a Pennsylvania Limited Winery, the education keeps coming.  Selling a bottle of wine comes with a great deal of “learning on the fly.” I honestly thought the problems I would have would be specific to how I make and cellar the wine, but the challenges I have had are mostly on the legal side with permits, licensing, taxes, and specifically labeling!

I’ve read the eCFR (Electronic Code of Federal Regulations) Title 27 → Chapter I → Subchapter A → Part 4 LABELING AND ADVERTISING OF WINE several times now.  This does not make me an expert.  These regulations were not meant for someone like me to easily comprehend or to use as a check list.  They are more like reference material to keep me out of trouble.  When in doubt, I called the TTB (Alcohol and Tobacco Tax and Trade Bureau) ... at least three times so far. 

Marketing folks would say the most important part of your label is that it catches peoples’ eyes or attains/maintains branding, but for the government the most important part is content.  Focus on the mandatory content and let the artist design your brand label … after the content is approved.  This will save you money!  After sorting through all the details and complexities this is what I found to be most important: 

Mandatory content for my winery label includes alcohol content, the bottle size, the sulfite statement, the government health statement, the name and address of the winery (in that order), and an “acceptable” type or class designation of the wine.  

Because of the depth and complexity of the “acceptable” designation of wine, I first applied for an exemption of label approval which I could do if I only sell in Pennsylvania.  This would allow me to be exempt from the certificate of label approval – entirely! This means I could avoid having to document the appellation of origin (where the grapes are grown as opposed to where the wine is made) on my label. 

The “acceptable” designation can be as simple as Red Wine, Table Wine, Rose Wine, Pink Wine, or White Wine as long as the alcohol is more than 7% and less than 14%.  If you want to tell your customers more about the wine and want to add a grape type to your label (a varietal which has to be in the approved list - Subpart J—American Grape Variety Names) or a vintage (year harvested) you must add an appellation of origin. 

In order to add an appellation of origin which is a state or AVA (American Viticultural Areas), you must make your wine either in that place or make your wine in a county bordering that place.  The more prestigious AVAs are designated appellations of origin by the USA government. 

My fall grapes are grown in the Suisun Valley AVA in California, but I make the wine in Pennsylvania, which does not border California or the Suisun Valley AVA.  This means if I want to use the varietal name or a vintage for the grapes, I must look at a larger area such as ‘The United States’ or ‘American’ as an appellation of origin.   The appellation of origin must be on your brand (front) label and must be in the same visual area as the varietal name and/or the vintage. 

Further introspection led me to change my mind on the label certification:  I decided to also apply for a label where I needed a certificate of label approval (COLA), in fact I applied for 3.  I did this because I am experiencing the layering of government (Federal, State, and Local) and didn’t want a hiccough in the Pennsylvania government paperwork if they require something other than a certificate of label approval for those of us who got an exemption for the COLA. 

As my first test, I chose 2020 American Cabernet Sauvignon as my acceptable designation and that label was approved.  I am still up in the air about what I want to call my wine on the label so I am getting approval on a number of different options.  My latest application is using a “Fanciful Name” along with a vintage and no varietal.  This requires an appellation of origin so I have applied for 2020 Le Blend and below it “American” for the appellation.  I would have preferred “The United States” as the appellation but even though the regulations say you can use that, it is not available on the form drop down and if your label does not match your form you are not approved. (This I learned the hard way.) 

There are things that can be modified on your label without submitting for a second approval.  These are alcohol content, the bottle size, the sulfite statement, and the name and address of the winery, and of course your artwork.  A change in the varietal means a change in the “acceptable” designation of the wine and thus it must go through the approval process as a new label, so choose wisely. 

For me, I now have to go back to the artist with the 4 labels I have gotten approved and ask her to design around the mandatory label content. I still don’t know what to call my wine since none of it qualifies as “Table Wine” because my wines are mostly 15% Alcohol by Volume. I most likely will go the “Fanciful Name” route. Thankfully, the TTB gets back to you very quickly with your rejections and approvals!

You can find a great link to the government tools here … to help you on your label journey!

And…you can find my winery here.