WINEAMERICA LABEL PRIMER

Transcription

1 WINEAMERICA LABEL PRIMER TERMS DEFINITION NOTES APPLICATION Mandatory Information 27 CFR 4.62 On front label: Brand name, class and/or type, alcohol statement. Appellation of origin, as required in cases listed below. Anywhere on bottle: government warning, sulfites statement, bottling statement, and net contents. Every letter of all mandatory information (except the alcohol statement) must be a minimum of two millimeters (mm) for standard bottle sizes. If mixed case lettering is used, TTB measures a lower case letter to determine the height of text. Brand Name 27 CFR 4.33 MANDATORY INFORMATION, ON FRONT LABEL The name under which the product is sold, such as if Chateau California bottles for Restaurant Italy, then Restaurant Italy is the brand name. The brand name is the name that is prominently displayed on your front label and how the product is marketed. If the product is not sold under a brand, the name of the bottler becomes the brand. Item 5 specify the exact designation from your front label. Class and/or Type 27 CFR 4.34 CLASS: grape, table, light, white, red, pink, amber, rose or dessert followed by the word wine may be used. TYPE: 75% grape varietal ( Chardonnay , 4.23a), 75% generic ( Vermouth ), 75% semi-generic ( Chablis ), or 75% non-generic of geographic significance ( Bordeaux ). The class or the type of the wine must be identified on the label. When using a type designation, you must also include an appellation of origin (4.25, 4.25a) in direct conjunction to the type designation. Alcohol Content 27 CFR 4.36 Stated as a percent of volume ( alcohol 12% by volume ) or as Table Wine or Light Wine if the wine has an alcoholic content between 7-14%. Can be abbreviated as Alc. % by Vol. When using either table wine or light wine, every letter must be a minimum of 2 mm. However, when stating the alcohol content as a percent of volume, each letter must be a minimum of 1mm and maximum of 3 mm. Item 12 Though it does not say mandatory on the application, TTB does want this filled in anyway. Appellation of Origin 27 CFR 4.25, 4.25a and 9.1 An appellation of origin can be the country (75% a), state (75% a), county (75% a) or the approved American viticultural area (85% - 9.1) in which the grapes were grown. Only mandatory if a type, vintage date, or the term estate is used on the label. When using a type designation or a vintage date, an appellation of origin must be in direct conjunction to the class or type designation. A viticultural area is also required to be in direct conjunction to any references to estate (i.e., estate bottled ). When applying for an exemption from label approval (see qualifications below) for sale in your state only (Item 16b of the COLA), an appellation of origin is not required on the label. Government Warning 27 CFR MANDATORY INFORMATION, ANYWHERE ON BOTTLE 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. On containers of 237 milliliters and less, every letter must be a minimum of 1 mm. In containers above 237 milliliters up to 3 liters, every letter must be a minimum of 2 mm. In containers above 3 liters, every letter must be a minimum of 3 mm. See regulations concerning maximum letters per inch. When submitting black and white printer s proofs of a label, the two words GOVERNMENT WARNING must clearly be bolder than the rest of the text, or TTB will reject it.

2 Sulfites Statement 27 CFR 4.32(e) CONTAINS SULFITES - Every letter must be a minimum of 2 mm. Be careful not to place the sulfite warning too close to the GOVERNMENT WARNING, as they must be separate and apart. Put the two statements on different lines and leave space between them. Bottling Statement 27 CFR 4.35, 4.35(a) The name and address of the bottling winery ( ABC Winery Anytown, CA ) must be on the label preceded by the words bottled by. Other operations may also be included (vinted, cellared, produced), as long as the bottling winery meets the definitions in 4.35 or 4.35(a). The name of the bottler must appear on the label exactly as it appears on the Basic Permit. It may be either the corporate name, trade name, or doing business as (dba) that is on the basic permit or that has been approved by your regional TTB as an amendment to the basic permit of the bottling winery. (I.e., Bottled by Chateau is not correct if the permit reads Chateau, Inc. ) The bottling statement (company, city, state) must be identical to that which is listed in Item 7. If the name used in the bottling statement and Item 7 is a recent addition to the basic permit (within the past 6 months), attach a copy of the approved amended permit to the label application. Net Contents 27 CFR 4.73 The statement of net contents must be on the label or blown into the container itself, and expressed in millimeters: 50 ml; 100 ml; 187 ml; 375 ml; 500 ml; 750 ml; 1 liter; 1.5 liter; 3 liter; or in even quantities of liters (4, 5, 6 ). Most 750 ml bottles have this blown into the bottle itself. If the net content statement is blown into the bottle and not on the label, write Statement of net contents blown into bottle, 750ml. in Item 18. Aging Any reference to this term on a front label or prominently displayed on a back label must be qualified with the amount of time aged in months or years. USE OF MISCELLANEOUS INFORMATION For example, Barrel aged 5 months. If blending aged with non-aged wine, the percentage that was aged must be stated: 20% aged in oak for 8 months. No amount of time is required after the statement Barrel Fermented Aperitif Dessert Wine Direct Conjunction TTB defines an aperitif as over 15% alcohol, made from grape wine containing brandy or alcohol, and flavored with herbs and other natural flavorings. A dessert wine must have an alcoholic content above 14% by volume. The TTB definition is the consumer is likely to see both items of information simultaneously The type must be in direct conjunction to the appellation, as must be the class if a vintage date is used. Aperitif can be used to describe, rather than identify the wine without it fitting the definition (i.e. enjoyable as an aperitif ). Even on the back text, do not describe a wine as a dessert wine unless it is over 14% alcohol. You may say, this wine is enjoyable with dessert. HAPPY WHITE (brand name) Washington, DC (appellation of origin) 1997 (vintage) Chardonnay (type designation) Alc 12% by Vol (alcohol statement) 1) Terms listed in bold type are defined elsewhere on chart. 2) Numerical citations refer to the TTB regulation, as cited in 27 Code of Federal Regulations (27 CFR). Copies can be obtained through the Government Printing Office ( ).

3 TERMS DEFINITION NOTES APPLICATION Estate 27 CFR 4.26 To use the term estate, the bottling winery must (1) be located in the labeled viticultural area; (2) have grown all the grapes used to make the wine; and (3) have crushed the grapes, fermented the resulting must, and finished, aged, and bottled the wine in a continuous process with the wine at no time having left the premises of the winery. USE OF MISCELLANEOUS INFORMATION When making any reference to estate, an approved American viticultural area (9.1) such as Napa Valley not California must appear in direct conjunction to the class or type designation on the front label. Exemption From Label Approval 27 CFR 4.70 This type of approval allows you to label the wine for sale in the bottling winery s state only, not for sale in interstate or foreign commerce. You are exempt from all requirements of an appellation of origin except for the use of estate. Fill in Item 17b. For sale in only. Formula Expedite Request The following types of wines require a wine formula approval prior to label submission (1) agricultural wine (honey, rhubarb); (2) other than standard wine (mixing wines from different classes); (3) flavored wine; (4) non-beverage wine; (5) high fermentation wine. When a winery can document a need to have a label approval in less than 3-4 weeks (current standard TTB turn-around time), it is possible to request that your label approval be expedited. If a fruit, berry, or citrus wine is made from blending two or more kinds of the same wine such as apple wine blended with cherry wine a formula is required. If the wine is produced by the fermentation of two or more juices of the same kind such as apple juice and cherry juice are blended and then fermented No formula is required. Write a letter to the TTB Advertising Labeling and Formulation Division on your winery letterhead, explaining why you are requesting expedited service. For example, if your product must be at the distributor by June 30, and the printing, bottling, labeling, and delivery or the product will take 12 days, ask for approval by June 18. End the request with an appreciative thanks for their assistance with this matter, and be sure to attach scheduling documentation. Health-Related Statements TTB will evaluate the use of health-related statements on a case-by-case basis. All statements must meet the following criteria 1) is truthful and substantiated by scientific or medical evidence; 2) discloses the health risks associated with both moderate and heavier levels of alcohol consumption; and 3) outlines the categories of individuals for whom any alcohol consumption poses risks. All the statements must be in direct conjunction and appear equally prominent.

4 Imported Wine Wine can be imported to the U.S. either in containers ready for consumption or in bulk. To find out the labeling requirements for imported wine or to export to a specific country, call the TTB International Trade Division in Washington at (202) or the WineAmerica office prior to your import/export. Registration for foreign food facilities (wineries) and prior notification of imports is required on all imports of wine. All labeling of the product must conform to the country of origin s labeling regulations as well as all U.S. labeling regulations. The product must be labeled with product of country. If imported in containers ready for consumer use, it must be labeled with an importers statement ( imported by company, city, state ) in addition to the bottling statement. All imported bottled wine label applications are submitted to TTB by the importer under their importer permit. Item 7 (importer permit) must match the importers statement on the label. Lab Analysis Wine (except honey wine) labeled without a sulfite declaration requires a lab analysis to confirm less than ten (10) parts per million sulfur dioxide. Late Harvest or Ice Wine The use of either term requires a harvest and residual sugar statement. TTB has defined Ice Wine as wines made from grapes that were partially frozen on the vine. Wines made from concentrate or which have been sweetened or fortified may not use Late Harvest, Ice Wine or similar terms. Artificially frozen grapes may not use the term Ice Wine. The two statements can appear as degrees brix or as percent by weight and should be written as Harvest Sugar 30 brix, Residual Sugar 10 brix, or abbreviated as: har sug 12% by wt. (by vol.) res sug 4% by wt. (by vol.). Lively TTB will allow the use of lively on still wines provided that it is not used in such a way that is likely to mislead consumers to believe the wine is effervescent. Each use of lively on a still wine label will be examined on a case-by-case basis. Meritage The term Meritage is not acceptable as the class/ type designation for wine. It may appear as additional information only such as a fanciful name. When used on the front/brand label Meritage may not appear on the same line as the class/type designation or with table wine; light wine; white wine; or red wine. Multiple Appellation of Origin 27 CFR 4.25, 4.25a When using a multiple appellation of origin you must state the percentages of each and it must total 100%. You can use the appellations from the state the winery is located in and any contiguous state, as permitted by individual states laws. Multiple Varietal 27 CFR 4.34 You can use a multiple varietal as your type designation, or make reference to another varietal, as long as you list them in order of highest to lowest with corresponding percentages, and the total must equal 100%. If you reference a varietal on the side text that is different from the varietal on the front, you must include percentages and it must total 100%. Organic Effective October 21, 2002 all label approvals that make an organic claim have been revoked by operation of regulation. All organic claims must now comply with the United States Department of Agriculture (USDA) regulations relating to the Details about the labeling requirements and certification process can be found at the NOP website at Labels that bear an organic claim are now be required to show a complete ingredient statement on the label. Organic claims must be documented with certification from a USDAaccredited certifying agent which must be attached to the COLA when submitted to TTB.

5 National Organic Program (NOP) at 7 CFR Part 205. Personalized Labels You can have a label approved with all the mandatory information on it that has an additional blank area for personalizing. The approval allows you to fill in the blank area with any personalized message within reason that is not considered misleading or unacceptable on a wine label. Once approved, you may not move anything on that label; you may only add the personalized message to the blank area (i.e., peoples names, company name, dates of events, logos and pictures). A separate approval is required for each different class, type, or label design. In Item 18, write Personalized Labels. Qualifications & Termination Dates There can be qualifications that the bottler must meet in order to label the product with the approved label. If there is a date in the termination box of your label approval, the approval expires on that date. You can no longer bottle/label wine or remove it from a bonded premise without filing a new application correcting what is listed in the qualification box. Example: When new labels are printed all letters of the bottling statement must be a minimum of 2 millimeters. The qualifications and termination date (if any appear) are located above the section where the label is affixed to the form as For ATF Use Only Qualifications and Termination Date. Still Wines TTB will not allow the use of any term on a wine label that implies that the wine is effervescent. TTB has determined that the following terms may not appear anywhere on the label of a still wine: bubble; bubbly; crackling; cremant; effervescent; frizzante; perlante; petillant; reciotto; sparkle; sparkling; spumante; sprity; spritz; tingle; tingly. This is not an all-inclusive list. Strong or Powerful TTB does not allow references to the intoxicating properties of alcoholic beverages. TTB rejects any use of the words strong or powerful (including descriptors such as strong notes of oak, for example) to preclude any misinterpretation of these terms. Vineyard (or orchard, ranch, or farm) Designation 27 CFR 4.39m A reference to the specific vineyard where the grapes were grown. To use a single vineyard designation, not less than 95% of the grapes used to make the wine must come from that vineyard. When using more than one vineyard designation on the label, the corresponding percentages must be stated from highest to lowest and equal 100%. Vintage Date 27 CFR 4.27 When referencing a vintage (95% of the grapes grown in one year) on the label, you must also include an appellation of origin that is more specific than a country in direct conjunction to the class or type designation on the front label. The vintage can appear anywhere on the front label; it is only the class or type designation and the appellation of origin that must appear in direct conjunction to each other. NOTE: Fruit wines cannot be vintage dated. Item 14 1) Terms listed in bold type are defined elsewhere on chart. 2) Numerical citations refer to the TTB regulation, as cited in 27 Code of Federal Regulations (27 CFR). Copies can be obtained through the Government Printing Office ( ).

6 Label Submission Nuances

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9 Online Label Submission - File Preparation Tips Each component of the label l (front/brand, strip, neck, back) must be saved as a separate jpg file. The color mode of the image must be RGB (screen color mode). If your file is in CMYK (four-color printing mode) it will make your file larger and you may exceed the 450kb file size limit. For example, a label file that is 394kb in RGB becomes 525kb in CMYK Save the file at its actual print dimensions (example 2.66 x 3 ) and a resolution of 120 dpi (or ppi).

10 Online Label Submission - File Preparation Remember that you must begin with a file that is at least as large as what you want to end up with- there is a fixed relationship between dimension and resolution. In order to maintain image quality, when you increase one you must decrease the other. If your image editing software gives the option to resample image when resizing, use this option only if you are trying to decrease the image dimensions or resolution. If you resample when increasingi image size or resolution you will degrade the quality of the image.

11 Online Label Submission - File Preparation When you submit your application online you will be have to browse to each label file to upload it. Remember to name your files in a way that will allow you to identify the right image when you upload (ex. 06_CaveB_Merlot_strip.jpg) You will also be asked to provide the print dimensions of each image, so have that information at hand.

12 FOR TTB USE ONLY TTB ID 1. REP. ID. NO. (If any) CT OR PLANT REGISTRY/BASIC 3. SOURCE OF PRODUCT PERMIT/BREWER'S NO. (Required) (Requir Domestic Imported OMB No (01/31/2009) DEPARTMENT OF THE TREASURY ALCOHOL AND TOBACCO TAX AND TRADE BUREAU APPLICATION FOR AND CERTIFICATION/EXEMPTION OF LABEL/BOTTLE APPROVAL (See Instructions and Paperwork Reduction Act Notice Below) PART I - APPLICATION 8. NAME AND ADDRESS OF APPLICANT AS SHOWN ON PLANT REGISTRY, BASIC PERMIT, OR BREWER'S NOTICE. INCLUDE APPROVED DBA OR TRADENAME IF USED ON THE LABEL (Required) 4. SERIAL NUMBER (Required) YEAR - 6. BRAND NAME (Required) 5. TYPE OF PRODUCT (Required) WINE DISTILLED SPIRITS MALT BEVERAGES 8a. MAILING ADDRESS, IF DIFFERENT 7. FANCIFUL NAME (If any) 9. ADDRESS 10. FORMULA/SOP NO. (If any) 12. NET CONTENTS 13. ALCOHOL CONTENT 15. WINE VINTAGE DATE (If on label) 16. PHONE NUMBER ( ) 11. LAB. NO. & DATE/PRE- IMPORT NO. & DATE (If any) 14. WINE APPELLATION (If on label) 17. FAX NUMBER ( ) 18. TYPE OF APPLICATION (Check applicable box(es)) a. CERTIFICATE OF LABEL APPROVAL b. CERTIFICATE OF EXEMPTION FROM LABEL APPROVAL "For sale in only" (Fill in State abbreviation) c. DISTINCTIVE LIQUOR BOTTLE APPROVAL. TOTAL BOTTLE CAPACITY BEFORE CLOSURE (Fill in amount) d. RESUBMISSION AFTER REJECTION TTB ID 19. SHOW ANY WORDING (a) APPEARING ON MATERIALS FIRMLY AFFIXED TO THE CONTAINER (e.g., caps, celoseals, corks, etc.) OTHER THAN THE LABELS AFFIXED BELOW, OR (b) BLOWN, BRANDED OR EMBOSSED ON THE CONTAINER (e.g., net contents, etc.). THIS WORDING MUST BE NOTED HERE EVEN IF IT DUPLICATES PORTIONS OF THE LABELS AFFIXED BELOW. ALSO, PROVIDE TRANSLATIONS OF FOREIGN LANGUAGE TEXT APPEARING ON LABELS. PART II - APPLICANT'S CERTIFICATION Under the penalties of perjury, I declare: that all statements appearing on this application are true and correct to the best of my knowledge and belief; and, that the representations on the labels attached to this form, including supplemental documents, truly and correctly represent the content of the containers to which these labels will be applied. I also certify that I have read, understood and complied with the conditions and instructions which are attached to an original TTB F , Certificate/Exemption of Label/Bottle Approval. 20. DATE OF APPLICATION 21. SIGNATURE OF APPLICANT OR AUTHORIZED AGENT 22. PRINT NAME OF APPLICANT OR AUTHORIZED AGENT PART III - TTB CERTIFICATE This certificate is issued subject to applicable laws, regulations and conditions as set forth in the instructions portion of this form. 23. DATE ISSUED 24. AUTHORIZED SIGNATURE, ALCOHOL AND TOBACCO TAX AND TRADE BUREAU QUALIFICATIONS FOR TTB USE ONLY EXPIRATION DATE (If any) AFFIX COMPLETE SET OF LABELS BELOW (See General Instructions 4, 6 and 7) TTB F (6/2006) PREVIOUS EDITIONS ARE OBSOLETE

13 I. PURPOSE OF THIS CERTIFICATE This certificate is required for and authorizes you to bottle and remove the product identified on the certificate from the bonded area of the plant(s) identified on the certificate where it was bottled or packed, or from Customs' custody. NOTE: This certificate does not constitute trademark protection. II. CONDITIONS OF THIS CERTIFICATE A. This certificate does not relieve you from liability for violations of the Federal Alcohol Administration Act, the Alcoholic Beverage Labeling Act of 1988, the Internal Revenue Code, related regulations, or rulings. B. You must ensure that: 1) all the information on your application is true and correct and 2) any and all information (including words, text, illustrations, graphics, etc.) shown or presented on the label(s) affixed to this certificate is truthful, accurate and not misleading. III. INSTRUCTIONS FOR COMPLETING AND SUBMITTING THIS APPLICATION NOTE: Applications may be filed electronically by accessing the TTB website at A. GENERAL INSTRUCTIONS 1. You must print or type your application and sign it in ink. Submit your application in duplicate to the ADVERTISING, LABELING AND FORMULATION DIVISION, ALCOHOL AND TOBACCO TAX AND TRADE BUREAU, 1310 G Street, N.W., Fourth Floor, Suite 400, Washington, DC (paper filers only) 2. You may use exact copies of TTB F in lieu of an original form. Copies do not have to include the instruction page; however, you remain subject to all the provisions and instructions outlined on the form. We suggest that you use an original form whenever possible. See Section IV for how to obtain a supply of forms. (paper filers only) 3. Generally, the person, firm, or corporation who will bottle or pack the product must file the application. However, for a product to be imported in containers intended for sale at retail, the application must be filed by the importer. In the case of a product to be relabeled, the application must be filed by the wholesaler. 4. You must firmly affix (with glue or tape - DO NOT STAPLE) all labels that will appear on the container. Printer's proofs and photocopies are acceptable. If labels are in the form of can flats, photocopies are requested. (paper filers only) 5. You may NOT make pen and ink changes, white out information, type-over, cross out information, and/or paste information over labels affixed to this application. (paper filers only) 6. You must reduce oversized labels so that they fit on the space provided. You must indicate in Item 19 that labels have been reduced and the percentage of reduction. 7. If your label is etched, embossed, or painted directly onto the container, or is clear acetate, you must submit a photograph of a filled representative bottle so that we may determine contrast and legibility of mandatory information. Photos should clearly show each side of the container that contains label information. B. SPECIFIC INSTRUCTIONS ITEM 1. Applicable only for applications submitted by a third party. The third party will complete this item. ITEM 2. Enter your plant registry number, basic permit number, or brewer's notice number as applicable. Wholesalers applying to relabel should enter the wholesaler's basic permit number. If you intend to bottle at more than one of your locations (distilled spirits and malt beverages only), show the registry number/brewer's notice number of each location where the product will be bottled. In this instance, Item 8 should reflect your principle place of business. ITEM 3. Indicate the source of product by checking the appropriate box. ITEM 4. You must assign a sequential serial number beginning with the last two digits of the current calendar year to each application and its duplicate, not to exceed 6 characters; e.g., 02-1, 02-2, etc. ITEM 5. Indicate the type of product by checking the appropriate box. For Sake, check the "wine" box. ITEM 6. A brand name is the name under which the product is sold. If the product is not sold under a brand name, the name of the bottler, packer, or importer becomes the brand name. ITEM 7. A fanciful name is a name that further identifies the product and is required for some specialty products. It is optional for other products. ITEM 8. Indicate your company name and current physical address exactly as they appear on your plant registry, basic permit, or brewers notice (include your approved DBA or trade name if you use it on the label). In the case of distilled spirits and malt beverages bottled at more than one location, indicate your principle place of business address. A separate mailing address may appear directly under the required name and address in Item 8a. ITEM 8a. You may use Item 8a to reflect additional registry numbers/brewer's notice numbers if the space provided in item 2 is insufficient. In this instance, cross out the words "Mailing Address, if different". ITEM 9. Provide the address of the person responsible for the application. ITEM 10. For any domestic wine and distilled spirits product requiring a formula, you must show the formula number. You must also attach a copy of the approved formula (except for vermouth) to your application. For domestic formulated products not manufactured by the applicant, a copy of the approved formula is requested but you may substitute a statement giving the name and address of the producer and the formula number. For any domestically produced flavored malt beverage product or any domestically produced malt beverage marketed under any name other than beer, lager, stout, etc., you must submit a copy of the approved statement of process (SOP). You must also show the SOP number. Do not submit your application for label approval until your formula or SOP is approved. ITEM 11. For products requiring a lab analysis, indicate the lab number and date of approval. For products requiring pre-import approval, indicate the pre-import number as indicated on the letter. A copy of this letter must be attached to the application at the time of submission. Do not submit your application for label approval until your preimport letter is received. ITEM 12. Indicate the size (net contents) covered by label(s) affixed to the application. You may submit a range of sizes, if known, at the time of submission of the application. You must indicate in ITEM 19 if the net contents are blown, branded, or embossed in or on the container. ITEM 13. Enter the alcohol content stated on the label. ITEM 14. Fill in only if a wine appellation of origin is stated on the label. ITEM 15. Fill in only if the wine vintage date is stated on the label. ITEM 16. Provide the phone number of the person responsible for the application. ITEM 17. Provide the fax number of the person responsible for the application. ITEM18. You must check "a" OR "b". You must also check "c" if you intend to bottle distilled spirits in a distinctive container. You must check "d" and enter the TTB ID number as shown in the upper left hand corner of the rejected application if you are submitting an application that was previously rejected. You must also check a, b, or c to indicate the type of application you are resubmitting. If you check "b": 1) you may only sell your product in the State where it is bottled AND 2) the statement "For sale in only" (using State abbreviation) must appear on each container. We do not issue certificates of exemption for products imported in bottles or for malt beverages. If you check "c", your application must include photographs of the front and back of the distinctive container. ITEM 19. The instructions for this item are on the front of the form. ITEM 20. Enter date application is prepared or submitted. ITEM 21. The applicant or authorized agent must sign in this block. ITEM 22. Signer's name must be printed in this block. TTB F (6/2006)

14 IV. CONTACT INFORMATION For Additional Information Contact: For A Supply Of This Form (TTB F ) Contact: Advertising, Labeling and Formulation Division (ALFD) The form may be ordered electronically by accessing the TTB web site at Alcohol and Tobacco Tax and Trade Bureau G. Street, N.W., Fourth Floor, Suite 400, The form may be electronically accessed at the Washington, DC TTB web site Phone (202) (Toll Free) address alfd@ttb.gov V. ALLOWABLE REVISIONS TO APPROVED LABELS The label(s) identified on and affixed to this certificate may be revised without re-approval as follows: NOTE: Any revision(s) you make to your approved label(s): 1) may not compromise the truthfulness or accuracy of the information presented on the label AND 2) may not be misleading as to the identity, origin, age, or other characteristics of the product. YOU MAY... WINE REVISION APPLIES TO DISTILLED SPIRITS MALT BEVERAGE COMMENTS 1. Delete any non-mandatory label information YES YES YES Includes words, text, illustrations, graphics, etc. 2. Change the shape or proportionate size of labels YES YES YES e.g., Change in size and shape of a bottle designed for a tall 3 liter bottle to fit a short, flat 500ML bottle 3. Change the stated percentages for varietal and/or appellation YES NO NO Must total 100% 4. Change the net contents statement YES YES YES Change the net content statement, except that separate applications must be submitted for containers of 237 ml or less, containers over 237 ml to 3 liters, and containers over 3 liters, to conform with the Alcohol Beverage Labeling Act of Change the stated alcohol content YES YES * Change may not alter: < Class and type < Taxable grade (for wine only) See Item #6 below 6. Add, delete or change the stated alcohol content NO NO YES Alcohol content is non-mandatory information for malt beverages 7. Add, delete or change the state bottle deposit information YES YES YES 8. Add, delete or change the statements required by the state in which the beer is to be sold 9. Change the name and/or tradename of responsible winery, DSP, brewery or importer 10. Change the statement of percentage of neutral spirits and name of commodity from which produced NO NO YES YES YES YES The name/tradename must appear on the Basic Permit or Brewer's Notice under which the certificate is issued NO YES NO Change may not alter the class and type 11. Change the stated mandatory period of age NO YES NO Change may not alter the class and type 12. Change the stated mandatory amounts of sugar at harvest and/or residual sugar YES NO NO See ATF Ruling 82-4 to determine when sugar statements are mandatory 13. Change the stated mandatory average analysis NO NO YES Changes must be in compliance with ATF Ruling Change the stated mandatory caloric content YES YES NO 15. Change the name and/or address of the foreign producer, bottler or shipper YES YES YES The producer, bottler or shipper must be located in the same country originally shown 16. Change or delete stated vintage date YES NO NO If vintage date is deleted no reference to "Vintage" may be made on any label or other materials (e.g. caps, celoseals, corks, etc.) affixed to the bottle 17. Add, delete or change the name and/or address or trademark (or both) of the wholesaler, retailer or persons for whom the product is imported or bottled 18. Change or delete stated bottling date YES YES YES 19. Change or delete stated amount of acid and/or ph level YES NO NO YES YES YES You may add this information by adding another label stating such information provided that no reference is made on the additional label to the product or any of its characteristics 20. Add or delete bonded winery number YES NO NO The bonded winery number must appear in direct conjunction with the bottler's name and address 21. Add, delete, or change UPC code YES YES YES Addition or change of UPC Code must be in compliance with Industry Circular Add, delete, or change a web site address, phone number, fax number or zip code 23. Change or delete a lot or batch identification number or other serial numbers 24. Add, delete, or change trademark and/or copyright symbols i.e., TM,, YES YES YES YES YES YES YES YES YES If you have questions about what is mandatory information and what is non-mandatory information, please contact ALFD. See Section IV for how to contact ALFD. PAPERWORK REDUCTION ACT NOTICE This request is in accordance with the Paperwork Reduction Act of We collect this information to verify your compliance with the Federal laws and regulations we administer for the labeling of alcohol beverages. The information is mandated by statute (27 U.S.C. 205) and is used to obtain a benefit. We estimate 31 minutes as the average burden for you to complete this form depending on your individual circumstances. You may comment to us about the accuracy of this burden estimate and suggest ways for us to reduce the burden. Address your comments or suggestions to: Reports Management Officer, Regulations and Rulings Division, Alcohol and Tobacco Tax and Trade Bureau, Washington, DC We may not conduct this collection of information, and you are not required to respond to this request, unless it displays a valid, current OMB control number. PRIVACY ACT STATEMENT We provide this information to comply with Section 3 of the Privacy Act of 1974 (5 U.S.C. 552a(e)(3)). We require this information under the authority of 27 U.S.C. 205(e). You must disclose this information so we may verify your compliance with the Federal laws and regulations we administer for the labeling of alcohol beverages. We use this information for the purposes described in the preceding paragraph. In addition, the information may be disclosed to other Federal, State and local law enforcement and regulatory agency personnel to verify information on the application and to aid in the performance of their duties. The information may further be disclosed to the Justice Department if it appears that the furnishing of false information may contribute to a violation of Federal law. Disclosure may otherwise be made pursuant to the routine uses most recently published in the Federal Register for ATF's Regulatory Enforcement Records System (Treasury/ATF.008). If you fail to supply complete information, then there will be a delay in the processing of your application. TTB F (6/2006)

15 U.S. may require more detailed alcohol labels AP staff and agencies 03 August 2007 By LAUREN SHEPHERD, AP Business Writer, 31 July 2007, 10:09 PM ET. NEW YORK - The Treasury Department is considering a new rule that would require companies to put alcoholic content, serving sizes and nutritional information on all alcoholic drink packaging. The labels would also include a "serving facts" panel, which would list the number of calories, carbohydrates, fat and protein for a standard serving size. Currently, labels on all liquor and on wine with more than 14 percent alcohol by volume must disclose at least the alcohol content, but that information is not required on beer labels, except in some states. However, if a brewer wants its beer to be labeled as a "light" beer, the label must show its caloric content and the percent of alcohol per volume. "Overwhelmingly, people want this kind of information on the package," Smith said. "This is the year 2007, and it ought to be on there," Smith said. "Our industry has not changed as quickly as it probably should have." The department said in the proposal that it would make the information labels mandatory three years after a final rule is published. The push for a more comprehensive label began in 2003 when the Center for Science in the Public Interest, the National Consumers League and more than 70 other groups and companies - including Diageo - petitioned the bureau to change the regulation. Treasury officials did not return calls seeking comment Monday