Is Your Brand Up To Date With Liquor Labeling Guidelines?

Distilled spirits make record sales year after year. In fact, spirits product sales hit a record $37.6 billion in 2022.

Those impressive statistics prove that the distilled spirits sector of the alcohol beverage market is growing and thriving. In this hot market, the right label is essential for your brand’s success — but does it also include all the required information? For your alcoholic beverages to hit the market with no issues, you must make sure you’re in the know and in compliance with liquor labeling requirements.

Brand Labels for Alcoholic Beverages

The label on your distilled spirits product should not only represent your brand and attract consumers, but it must be informative as well. In general, food and non-alcoholic beverage labels are a matter of public health, so the FDA monitors their product labels.

However, alcoholic beverages such as distilled spirits and malt beverages have additional labeling requirements. The Federal Alcohol Administration (FAA) Act proposes criteria for regulating the labeling and advertising of distilled spirits, and the Alcohol and Tobacco Tax and Trade Bureau (TTB) enforces them.

Alcoholic beverage product labels and their mandatory label information is taken very seriously by the TTB. It is illegal for wholesalers, bottlers, and even consumers to remove labels from distilled spirit products (per 27 CFR part 5). To avoid any issues when selling your alcohol products, take the time to learn mandatory label information and the process of being approved by the TTB.

Distilled Spirits Labeling Requirements

According to U.S. federal laws regulated by the TTB, you must place all mandatory label information within the same field of vision on your distilled spirits label. This means that all the required information should be visible simultaneously without having to turn the product’s container, but it can be placed on the front, back, or side label.

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Mandatory Labeling Information

As of March 2022, the most recent mandatory labeling requirements for your distilled spirits and malt beverages product labels dictate that the label must include the following information:

• • The product’s brand name which you are using for marketing the alcoholic product. If you don’t have a brand name, the name used on the front of the product label is considered the brand name.
  • The class or type designation of the distilled spirits.
  • The alcohol content of the product stated in percent alcohol by volume (abv).
  • Statements of age are needed for some distilled spirits, such as whiskey or brandy.
  • A color ingredient disclosure if you add coloring materials to your distilled spirits product. You can either specify which ones you’ve added or that the product is artificially colored.
    • Note: If you added FD&C Yellow #5, cochineal extract, or carmine to your distilled spirits, that is mandatory label information for your product’s label.
  • Treatment and flavoring with wood require the following disclosure statement: Colored and flavored with wood (type of wood product).
  • A disclosure statement if the distilled spirits product contains saccharin.
  • If the distilled spirit contains aspartame, the product label must state the following in capital letters and separate from all other mandatory labeling information: “PHENYLKETONURICS: CONTAINS PHENYLALANINE.”
  • A sulfite declaration if the spirits product contains ten or more parts per million sulfur dioxide.
  • A commodity statement (if applicable) to disclose the percentage of neutral spirits in the product.
  • The following health warning statement must be on all alcoholic beverages containing no less than 0.5% alcohol by volume sold or distributed in the U.S.: 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.
  • The company name and address of the distillery
  • Net contents
  • The country of origin for imported distilled spirit products that are either bottled, packed, or filled before or after importation.
  • The state of distillation is required for certain types of whisky whose country of origin is the United States.

If you want to use the term “low carb” as a health claim on your distilled spirits product label or in advertising, the TTB only approves if there are less than 7g of carbohydrates per 1.5 fl oz. Similarly, manufacturers can only label their alcoholic beverage as “gluten-free” if there are no ingredients that contain gluten.

Currently, alcoholic beverages are exempt from declaring food allergens and artificial flavorings on product labels, but that may change. Recently, the TTB has proposed that allergen labeling should be required on alcoholic beverage labels.

Distilled Spirits Labels Process of Approval

Whether you’re putting a new distilled spirits product on the market or revising an established alcoholic product’s label, you need to apply to the TTB for label certification first. The TTB will supply you with the proper application form for your distilled spirits product’s label either online or by mail, which you fill out and return. When your application is approved, TTB sends you a Certificate of Label Approval (COLA). In most cases, it takes approximately one week to get your distilled spirits label approval.

It’s important to follow TTB regulations when preparing labels of alcoholic beverages to avoid these common labeling issues that can cost you time and money:

• Distilled spirits label revisions that aren’t approved
• Missing alcoholic beverage labeling requirements
• Inaccurate alcohol content

Making Revisions to Distilled Spirits Labels

Depending on the changes you make to an existing distilled spirits product, you may need to revise your product label. In this case, you must submit a new application to TTB for certification and receive a COLA for your revised product label before distribution.

You must apply for a new COLA if you change or add the following:

• The class or type of distilled spirits statement
• The brand name
• The appellation of origin (wine only)
• The address statement (unless it’s in the same state as the old one)
• The bottler or importer
• New graphics, pictures, and representations (unless they’re holiday or seasonal)
• New wording, phrases, tests, certifications

Alcoholic Product Label Change Exemptions

There are some small changes you can make to your distilled spirits product label without having to reapply to TTB for a new COLA, such as:

• • Deletion of label information that isn’t mandatory
  • Repositioning of product label information
  • Change in color, shape, or size of product label
  • Change in font type and size, including changes to spelling, punctuation, upper case letters to lower case, etc.
  • Dividing a single COLA-approved product label into multiple product labels or vice versa (if they meet requirements)
  • Changing the Net Contents label
  • Adding a new Servings Facts Statement to the product label
  • The addition, deletion, or revision of the bottling date
  • Seasonal graphics or text

Liquor Labeling Solutions for Your Distilled Spirits

When you have the proper labeling equipment, it’s easier to keep your product labels up to date with TTB mandatory label requirements.

At CTM Labeling Systems, we have the solutions you need to handle bottles of any shape and size. Plus, you can place specialty product labels without interfering with your COLA-approved distilled spirit labels.

CTM Labeling Systems is here to help you comply with liquor labeling requirements and get you set up with the right equipment for your business. Contact us, and we’ll be happy to answer any questions you may have about applying your distilled spirits or alcoholic beverage labels.