This looks like a straightforward label, but it raises some good issues. “Napa” is on the “brand (front)” label. Should it be? On the one hand, it looks to be bottled in the Napa Valley. On the other hand, the appellation is California more broadly, as per box 14 of the label approval. The label mentions Napa three times, attesting to its obvious importance as a signal of quality.
Each reference to Napa tends to be accompanied by a clarifying explanation. One says it’s bottled there, two say the brand’s ownership is there. None of them (explicitly or by omission) suggest the grapes were grown there. TTB has approved quite a few labels presenting the same issues, and they may show a shift in policy, compared to five or ten years ago. It is our understanding that some wineries were blocked from highlighting Napa, regardless of the location of the bottling winery, if the grapes were from elsewhere.
The same label raises one more good (but rather technical) issue. The brand name and alcohol content statement are on one piece of paper. The varietal and appellation are on another. The rules require all four items to be on the brand label. Sometimes, TTB requires all four items on the same piece of paper, sometimes in the same field of vision. Here TTB allowed them to be divided across two pieces of paper in the same field of vision.
Robert C. Lehrman is the principal attorney at Lehrman Beverage Law, PLLC. Robert founded the firm in 2001 after 12 years at the Washington, DC office of a larger firm that specializes in federal and state administrative law. From 1998 until 2001 ... Read Full Bio