TTB’s Top Label Application Errors

Wine Institute’s Label Service Provides Valuable Guidance

Wine Institute has updated the Top Label Application Errors list compiled from recent data collected from the Alcohol and Tobacco Tax and Trade Bureau of the U.S. Department of the Treasury (TTB). The list is located on the Wine Institute website under member resources and also includes steps on how to avoid these common mistakes.

Wine Institute offers members the opportunity to submit their wine label applications for review by our Federal Compliance Program Manager, Susan Gregory, before submitting to the TTB. Susan has managed the Wine Institute’s Label Approval Service in the Washington, D.C. office since 2005 and is well versed in guiding members through the complex wine label application process.

The label review is an assessment of every mandatory and voluntary component on a label, including brand name, varietal and appellation statements, net contents, nutrition facts panel, ingredient/allergen statements, bottler’s statement and address line, all label text and claims (nutrient content, health, along with other regulated label statements such as certified sustainable, organic, etc.). Feedback is provided for out-of-compliance elements and Susan provides expertise for less defined areas of the regulations. She can also quickly assess if any changes to a member’s approved labels would require a new COLA submission.

Susan can assist members with requests for accelerated reviews of COLAs, formula applications, and trade/fanciful name searches. She acts as an advocate for individual members before the TTB, requesting second reviews of controversial labels and negotiating use/up approvals.

This guidance through the myriad of regulations, policies and unwritten expectations affecting a wine label will save time and avoid unnecessary delays. Additionally, Susan can respond to general permitting and taxation questions.