Everything You Need To Know About Labeling Requirements for Hard Liquor and Distilled Spirits
Each year, the Alcohol and Tobacco Tax and Trade Bureau (TTB) conducts the Alcohol Beverage Sampling Program (ABSP). This program gathers a random selection of spirits and tests them for compliance. Of the bottles selected, 40% are deemed to be in violation of labeling regulations in some fashion.
Which TTB label requirements are most commonly violated, and how can you avoid mistakes on your distilled spirits labels? Let’s take a look!
What Kinds of Errors Show Up on Liquor Labels?
The majority of labeling requirements for distilled spirits products fall under the jurisdiction of the TTB. Until 2016, the results of the ABSP were made public. Since then, the bureau has concentrated on working directly with violators to correct errors and introduce policies that address the most common problems found in spirits labeling.
Looking at the latest public data, issues with liquor labels were concentrated in three areas:
- Unapproved revisions
- Missing mandatory label information
- Inaccurate alcohol content (percent alcohol by volume)
Getting Labeling Revisions Right
Before you can label your product and sell it, you need to submit an application for certification to the TTB (www.ttb.gov). Once this application is approved, you will receive a Certificate of Label Approval (COLA). Processing times vary depending on current demand, however, it typically takes about a week to get approval.
In most cases, if you want to revise the alcohol beverage label, you need to submit a new application for certification and wait for a COLA before using the new design on your products. However, there are a few changes that can be made without re-approving your label:
- Dates and codes for bottling, production or expiration of the product
- Lot, batch identification and other serial numbers
- Names and addresses for the importer, producer, distributor or bottler
- Bottle deposit information
- UPC barcodes and mobile barcodes, including QR codes
- Contact information, including website addresses and phone numbers
- Trademarks, copyright symbols, kosher symbols, company logos and social media icons
- Information about awards given to the product
- Holiday or seasonal graphics and text
In general, if it doesn’t change the overall meaning of the label, it doesn’t need a new COLA. The easiest way to check if you are in compliance is by using the TTB’s revision tool.
What Information Do I Need on My Labels?
Required information for distilled spirit/liquor labels is detailed in the TTB’s Beverage Alcohol Manual (BAM). These items are required on all distilled spirits labels:
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- Brand name or trade name
- Class and type. (This is covered in Chapter 4 of the BAM.)
- Alcohol content in percent by volume. Proof is optional, but it must be paired with the ABV.
- Net contents stated in metric units, i.e. “750 mL”
- Name and address of the distiller for spirits produced in this country, or the importer of foreign spirits.
- Country of origin, including where the product was made and where it was bottled.
- A commodity statement, which identifies the type of distillation. This includes the grains used, such as wheat or rye whiskey, and whether the product was made using original distillation or redistillation.
- This health claims warning:
“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.”
These items are required on your liquor label only if they apply to your product, based on the alcohol type designation:
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- Disclosure of any dyes, coloring materials or other color additives.
- Treatment (flavoring) with wood, excluding contact with oak containers during storage. An exemption is made for brandy infused with oak chips.
- FD&C Yellow #5 disclosure for beverages containing this dye
- Saccharin disclosure
- Sulfite declaration
- Statements of age are required for whiskey aged less than 4 years, some brandies aged less than two years, and other distilled spirits with age references or a distillation date on the label.
- Whiskeys made in the United States must declare the state where the product was distilled.
The BAM also has text size requirements for each of these statements. Most items need to be at least 2mm tall on 200mL and larger bottles, and 1mm or taller on bottles that are smaller than 200mL.
In the bottles sampled by the last public ABSP, errors in almost every label category were present. That includes two bottles that had errors in the health warning statement, despite this statement being required on all alcoholic beverages.
Labeling Errors in Alcohol Content
Most spirits require a statement of alcohol by volume, written as “X% ALCOHOL (ALC) BY VOLUME (VOL).” If the product contains solid material, this statement must be “BOTTLED AT X% ALCOHOL BY VOLUME.” This includes spirits that contain sugar crystals, like Rock and Rye and some types of cinnamon schnapps.
The last public ABSP testing found that 50 of the 175 bottles tested had inaccurate alcohol measurements. This is a concern for wholesalers, retailers and customers who need accurate information to judge how much they can safely consume. It’s also a problem for federal and state governments, who tax beverages based on alcohol content. Under TTB regulations, the ABV stated on the alcohol beverage label can be as much as 0.15% lower than than the correct ABV, but it can never be over.
Methodology for proofing spirits is covered by Code of Federal Regulations 27 CFR Part 30, also known as the “Gauging Manual.” Since these errors are common, the TTB created a video series to go with this manual that covers different processes used to measure alcohol. (This includes using a densitometer or a hydrometer for measurements, as well as ways of getting accurate measurements from spirits containing dissolved solids.)
Using Your Labeling Equipment to Address Labeling Requirements
Choosing the right equipment doesn’t just improve the labeling process; it also helps to make adjustments and comply with TTB regulations while addressing errors as they appear.
For example, our wine bottle applicator is designed to handle curved glass bottles. It can be set up to apply front and back labels, or a single wrap label. If you need to correct an error on bottles that already have labels, this machine can apply cover labels that will bring bottles into compliance.
Since many distilleries produce a variety of spirits and brand labels, from tequila to cognac, the need for versatility is pretty widespread. Our vertical trunnion roller machine was originally designed for bottles of bourbon, and depending on how it’s configured, it can apply up to 5 labels on each bottle. The trunnion roller controls the movement of the bottle (so long labels won’t skew or flag, even at speeds up to 45 PPM), and using this machine, you can add more labels for special product runs, leaving your COLA-approved labels untouched.
Looking for something that can help with labeling rectangular bottles and labels? Our custom-designed labeling systems can be customized to fit the needs of your specific product and container. This option can be configured with 360a standard labelers or 3600a print-and-apply labelers (which means you can add expiration dates and other container-specific information to one label, while using a cheaper apply-only system for the other label).
Get a Labeling System that Fits Your Production Process
CTM Labeling Systems makes a range of machines for general use and specific tasks, so whether you’re labeling glass and plastic bottles used for specialty liqueurs, we’re your labeling partner in complying with liquor label requirements.
Contact us to be put in touch and we will happily answer your questions and put you in contact with one of our trusted distributors. They can help you set up a labeling system that meets the needs of your bottling business, from labeling the bottles themselves to identifying cases and pallets of finished products.
