Here we are, checking in a year later, after this post on GMO labeling. TTB still does not allow GMO labeling of the sort depicted above. This sort of labeling seems to be sweeping across the grocery store, but not in the alcohol beverage aisle. We have at least two bases for saying this. First of all, there is this recent Needs Correction (NC) notice. It says the GMO talk is misleading, therapeutic and not acceptable. Second, we checked through LabelVision and see essentially no GMO-related labels. It is pretty amazing that few if any seem to have slipped through, even though this list tends to say quite a few alcohol beverage products meet the Non-GMO Profect standards. This NC notice is good because it also happens to cover a few other issues....Continue Reading Leave a Comment
No GMO at TTB
Gluten Free Ruling
TTB announced a big policy change — about gluten free — just before the Memorial Day holiday weekend. For many years before the announcement, plenty of companies have tried to make “gluten free” claims, but we still didn’t see any approved TTB labels referring to “gluten free.” A few weeks back, we thought we had one, when we heard a lot of buzz about Omission beer as above. But alas, even the Omission label has had a big omission when it comes to this particular claim. All this is about to change in a big way, as result of this TTB Ruling, released late last week. As a result, we may begin to see various gluten free claims on TTB labels in the very near future. To show the earlier TTB policy, a fairly recent...Continue Reading Leave a Comment
The Triple Sec Lobby
The highly secretive and powerful Triple Sec lobby has struck again — this time to require at least one drop of triple sec in certain alcohol beverages. Google it as much as you wish, and you will find little about this uber-secret institution, rumored to have strong ties leading all the way back to France. That’s because it’s secret. Some even say that Sen. John Kerry, with his thinly disguised sympathies for many things French, is Triple Sec’s man in Washington. On a more serious note, for many years, TTB has required at least some triple sec in products that purport to be margaritas. The policy is here, at page 13 (scroll down to Margarita). The policy is in TTB’s “Beverage Alcohol Manual” for spirits. The BAM can be a handy resource to...Continue Reading Leave a Comment
Class & Type Must Stand Alone
In the above example, it is not sufficient to have VODKA on the front label. Or, the right size. In addition, it needs to be “separate and apart” from other matter. TTB has gotten more strict about this over the years. The above rejection is from a few days ago. The vodka label is from many years ago, to show the movement in the policy, or the enforcement of the policy.
TTB is quite concerned about word placement and proximity. For example, “absinthe” must appear next to other words, as here. Vodka may not, as above. It is important to understand the various proximity rules, because they can lead to unpleasant surprises, and because they extend from spirits to beer and wine. It is probably not okay to...Continue Reading Leave a Comment
Age Range on Wines
This Malvira red wine happens to mention that the Barbera d’Alba blend is “aged in French Oak barriques … for 18-24 months.” Is there anything so troublesome about that? Maybe so. On a similar label (with a different age range), the above rejection shows that TTB would prefer that wine labels show the actual amount of age, rather than a range or guesstimate.
TTB did not cite any specific authority in the rejection above, but 27 CFR 4.38(f) would make it hard for the importer to win this argument. It says:
(f) Additional information on labels. Labels may contain information other than the mandatory label information … if such information complies with the requirements … and does not conflict with, nor in any manner qualify statements required...Continue Reading Leave a Comment
Here are a few charity-themed alcohol beverage labels. They are becoming more common, to the point where TTB does have a specific policy. In general, of course the charity language has to be truthful and non-misleading — but also, it needs to have a bit of specific information (such as the name of the charity). Vets Vodka is bottled by Terressentia of North Charleston, South Carolina and benefits the National League of Families (POW-MIAs). Hope Wine is bottled by Sonoma Wine Company of Graton, California and benefits “our troops.” Third, Charity Case wine is made by One True Vine, LLC of St. Helena, California and benefits “charities serving children and families in and around Napa County.”Continue Reading Leave a Comment