TTB Compliance | What you need to know
In order for your labels to be Tax and Trade Bureau complaint, there are a few things your label needs to be up to TTB standards:
Brand Name: Name under which the product is sold.
Designation: ie. Red Wine, White Wine, Honey Wine, etc. or a statement of composition. ie. Grape wine with pineapple flavor
Appellation of Origin: An area where the fruit or agricultural product is used to make the wine. ie. Georgia, California, American
Percentage of Foreign Wine (if applicable)
Alcohol Content: ie. Alcohol ___% by Volume.
Net Contents: Volume of wine in the bottle. ie. 750ml, 1L, 350ml, etc.
Name and Address: The name and address (city & state) as listed on your permit.
Sulfite Declaration: Your label must include “Contains Sulfites” somewhere on the label. Most brands put it on the back near the Government Warning
Health Warning Statement: The Government Warning blurb. GOVERNMENT WARNING must be bold and capitalized.
GOVERNMENT WARNING: (1) According to the Surgeon General, women
should not drink alcoholic beverages during pregnancy because of the risk of
birth defects. (2) Consumption of alcoholic beverages impairs your ability to
drive a car or operate machinery, and may cause health problems.
Country of Origin: Imported wines only. Required by U.S. Customs and Border Protection. You must state the country of origin on the label if applicable.
FD&C Yellow #5: It is mandatory to have listed on your wine label ONLY if FD&C Yellow#5 is used in the wine. Most domestic wine does not have this ingredient.
Cochineal Extract or Carmine: It is mandatory to have listed on your wine label ONLY if it is used in the wine. Most domestic wine does not have this ingredient.
Important “Legal-ese” and Tips
If you're venturing into the world of winemaking, distilling, or brewing, compliance with TTB regulations is paramount. Here's what you need to know to stay on the right side of the law:
Obtain Proper Permits: Before you can legally produce and sell alcohol, you must obtain the necessary permits from the TTB. Depending on your operation and the type of alcohol you're producing, this may include a Brewer's Notice, Distilled Spirits Plant (DSP) Permit, or Winery Permit.
Submit Label Approvals: All alcohol labels must receive TTB approval before they can be used for commercial purposes. Submit label applications through the COLAs Online system, ensuring that your labels comply with TTB regulations regarding content, font size, health warnings, and alcohol content disclosures.
Maintain Records: Keep detailed records of your production processes, including ingredients, batch sizes, distillation methods, and storage conditions. Accurate record-keeping is essential for compliance with TTB regulations and can help you demonstrate compliance in case of audits or inspections.
Pay Excise Taxes: Alcohol producers are required to pay excise taxes on their products, which vary depending on the type and alcohol content. Familiarize yourself with TTB excise tax rates and deadlines to ensure timely payment and avoid penalties.
Adhere to Labeling Requirements: TTB regulations govern the content and design of alcohol labels, including mandatory information such as brand name, alcohol content, health warnings, and origin designations. Ensure that your labels meet TTB requirements to avoid delays in approval and potential fines.
Comply with Advertising Rules: Advertising alcohol comes with its own set of regulations, including restrictions on false or misleading claims, targeting minors, and promoting irresponsible consumption. Familiarize yourself with TTB advertising guidelines to ensure compliance in your marketing efforts.
Stay Informed: TTB regulations are subject to change, so it's crucial to stay informed about updates and revisions. Subscribe to TTB newsletters, attend industry seminars, and regularly check the TTB website for announcements and guidance.
Engage with TTB Resources: Take advantage of TTB resources and support services available to alcohol producers. Whether you have questions about regulations, need assistance with applications, or want to request guidance, the TTB is there to help.
Invest in Compliance Training: Ensure that you and your team are well-trained in TTB regulations and compliance procedures. Invest in training programs or workshops to enhance your understanding of regulatory requirements and best practices.
Seek Professional Guidance: When in doubt, don't hesitate to seek guidance from TTB consultants, legal experts, or industry associations specializing in alcohol regulation. Their expertise can help you navigate complex compliance issues and avoid costly mistakes.
By prioritizing TTB compliance in your alcohol production business, you demonstrate your commitment to legal and ethical practices, ensuring the integrity and safety of your products. Stay informed, stay compliant, and raise a glass to responsible entrepreneurship!
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