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TTB Alcohol Label Requirements: What Every Alcohol Label Needs

⚞ The Highlights:

The TTB (Alcohol and Tobacco Tax and Trade Bureau) regulates the labeling of most distilled spirits, wine, and malt beverages sold in the U.S.
Every alcohol label needs a core set of elements: brand name, class and type, alcohol content, net contents, name and address, and the Government Warning statement. Imports and certain products add more.
The Government Warning text is fixed by law. You can’t reword it, and it has strict rules for bold type, size, and legibility.
Most alcohol labels need a Certificate of Label Approval (COLA) from the TTB before you can sell the product.
The 2020 TTB final rule loosened where mandatory info can sit on the label and formalized personalized labels, which changed how brands can design and revise labels.

The TTB requires every alcohol label to carry a specific set of mandatory elements: brand name, class and type, alcohol content, net contents, the name and address of the bottler or importer, and the Government Warning statement. Most alcohol beverages also need a Certificate of Label Approval (a COLA) before they can go to market. Get one of those elements wrong and your COLA gets rejected, which pushes back your launch.

We print a lot of wine, spirits, and beer labels, so we sit right at the point where a compliance rule turns into a printed label. Below is a plain-language breakdown of what the TTB requires on an alcohol label today, how the COLA process works, what changed in the 2020 final rule, and the label-production details that trip brands up. One note up front: this is general guidance, not legal advice. For your specific product, confirm with the TTB or a compliance professional.

What is the TTB, and what does it regulate?

The TTB is the federal agency that oversees the labeling, advertising, and taxation of alcohol beverages in the United States. If you make or import spirits, wine, or beer for sale, the TTB’s labeling rules almost certainly apply to you.

What does TTB stand for?

TTB stands for the Alcohol and Tobacco Tax and Trade Bureau, a bureau of the U.S. Department of the Treasury. It was created in 2003 when the former Bureau of Alcohol, Tobacco and Firearms (ATF) was split, moving the alcohol and tobacco tax and trade functions to the TTB.

TTB or FDA: which agency regulates your beverage?

Not every drink with alcohol in it falls under the TTB. Jurisdiction depends on the product, and a few categories are regulated by the FDA instead. This matters because it changes which labeling rules you follow.

Product	Regulated by	Why
Distilled spirits	TTB	Covered by the Federal Alcohol Administration Act
Wine at 7% ABV or above	TTB	Meets the FAA Act definition of wine
Wine below 7% ABV	FDA	Falls outside the FAA Act, so it follows FDA food-labeling rules
Malt beverages made with malted barley and hops	TTB	Meets the FAA Act definition of a malt beverage
Beer made without malted barley or hops	FDA	Doesn’t meet the malt-beverage definition, so it’s an FDA food

If your product sits in an FDA category, you follow FDA food-labeling rules instead, which include a Nutrition Facts panel and a full ingredient list. For a deeper look at where this line falls for a specific category, our guide to hard cider label requirements walks through a product that can land on either side.

What are the mandatory elements on an alcohol label?

The TTB requires a core set of elements on every alcohol label, and they generally have to appear together in the same field of vision (one side of the container you can read without turning it). Here’s what each one means.

Brand name

The name the product is marketed under. It can’t mislead the consumer about the product’s identity, origin, age, or other characteristics.

Class and type

What the product actually is: bourbon, vodka, gin, red wine, malt beverage, and so on. Spirits and wines have federal standards of identity that define what can be called what, which is why a “vodka” has to meet the definition of vodka to be labeled that way.

Alcohol content

The alcohol by volume (ABV), shown as a percentage. Distilled spirits also commonly show proof. There are tolerances for how far the stated number can sit from the actual number, and those tolerances tightened in the 2020 rule (more on that below).

Net contents

How much liquid is in the container, usually in metric units like milliliters or liters. Some products still have standards of fill, meaning only certain container sizes are allowed.

Name and address

The name and address of the bottler, packer, or importer responsible for the product. For imports, this identifies the U.S. importer.

The Government Warning statement

Required on every alcohol container sold in the U.S. under the Alcoholic Beverage Labeling Act of 1988. The text is fixed by law and cannot be reworded, paraphrased, or shortened:

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 formatting rules are just as strict as the wording. “GOVERNMENT WARNING” has to be in bold capital letters, the statement has to be separate from other information on the label, it has to sit on a contrasting background so it’s readable, and there are minimum type sizes based on container size. This is one of the most common places a label slips out of compliance, which we’ll come back to.

Country of origin and other conditional elements

Beyond the core elements, some products need more depending on what they are and where they’re made:

Country of origin for imported products.
State of distillation for certain American whiskeys.
Sulfite declaration when sulfites are present at or above the threshold.
FD&C Yellow No. 5, cochineal/carmine, and aspartame disclosures when used.
Age statements when required, or when you choose to make an age claim.
Commodity-specific statements like “colored and flavored” or neutral-spirits declarations where they apply.

Worth knowing: “Mandatory” isn’t one fixed list for every bottle. The core elements apply to almost everything, but the conditional elements depend on your product, your ingredients, and whether it’s imported. When in doubt, check your product’s specific commodity page on TTB.gov or ask a compliance pro before you print.

A six-pack of beer with holographic labels.

What is a COLA, and do you need one?

A COLA is a Certificate of Label Approval, the TTB’s sign-off that your label meets federal requirements. Most alcohol beverages need an approved COLA before they can be sold or shipped across state lines. You submit your label to the TTB, they review it, and you either get an approval or a rejection with the reasons why.

How does the COLA process work?

You (or your compliance team) submit the label through the TTB’s COLAs Online system with an image of the label and the required product details. The TTB reviews it against the rules for that commodity. Approval times move around depending on volume and the product type, so it’s worth building COLA review into your launch timeline rather than treating it as a last step.

What gets a COLA rejected?

Most rejections come down to small, fixable label details, not big mistakes. That could be a missing mandatory element, a Government Warning that’s too small or not bold, an alcohol content outside tolerance, a class-and-type statement that doesn’t match the standard of identity, or a brand claim that reads as misleading. Because we print these labels, we see the same handful of issues over and over, and almost all of them are cheaper to catch before the label goes to the TTB than after. Our post on why the TTB turns down COLAs digs into the most common ones.

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What changed in the 2020 TTB final rule?

In April 2020, the TTB published a final rule that modernized and reorganized its labeling and advertising regulations. It was the biggest update to these rules in decades. It followed a 2018 proposal and a round of industry feedback. A few of the changes are worth knowing because they affect how you design and revise labels today.

More flexible placement (field of vision)

The rule relaxed where mandatory information has to appear. Instead of forcing certain items onto the brand label, it lets the required elements sit anywhere within a single field of vision: one side for a flat container, or roughly 40% of the circumference for a cylindrical one. That gives designers more room to work.

Personalized labels

The rule formalized personalized labels, meaning a label that meets the mandatory requirements but gets customized for a customer with a message, name, artwork, or date. Under the approved process, those personal touches can change without triggering a brand-new COLA, which is useful for wedding, corporate, and gift runs.

Standards of identity updates

Several product definitions were updated. The rule recognized “agave spirits” as a class covering tequila and mezcal, removed the old requirement that vodka be without distinctive character, aroma, taste, or color, and loosened rules around age statements so that all time in oak can count toward age.

Alcohol content tolerance

The rule set the allowable tolerance for distilled spirits alcohol statements at plus or minus 0.3 percentage points, giving producers a clear, consistent range for how close the stated ABV has to be to the tested value.

Other updates

The rule also extended country-of-origin labeling to imported wines and malt beverages, dropped the ban on strength claims like “strong” for malt beverages, and cleaned up a number of older classifications. The direction is more flexibility for producers. The core consumer-protection requirements stayed the same.

The label-production side of staying compliant

Compliance isn’t only about what the rules say. It’s about what actually prints on the label and survives your run. This is the part brands tend to learn the hard way, and it’s where a printer who knows the TTB rules earns their keep.

Common label mistakes that trigger rejection

Government Warning too small or not bold. The type-size minimums are real, and shrinking the warning to fit a design is a fast way to a rejection.
Low contrast. A warning printed in a color too close to its background can fail the legibility requirement even if the size is right.
Elements split across fields of vision. Mandatory items that aren’t grouped where the consumer can read them together.
Class and type that doesn’t match the standard of identity. Calling a product something it doesn’t legally qualify as.
ABV outside tolerance. A stated number that doesn’t hold up against the tested value.

How allowable revisions and personalized labels affect your print run

The 2020 rule’s personalized-label and allowable-revisions provisions matter on the production floor, not just on paper. If you know which changes you can make without a new COLA (a personalization, a minor allowable revision), you can plan short, flexible runs, like a customized gift batch, without restarting the approval clock. If you don’t, you can end up waiting on a COLA you didn’t actually need, or shipping a change that did need one. It’s worth confirming which bucket your change falls into before you print.

Pro tip: Send your printer the exact approved COLA image, not just your design file. Matching the printed label to the approved label is what keeps you compliant after approval, and it’s the easiest way to avoid a mismatch between what the TTB signed off on and what actually ships.

A collection of wine bottles with labels that meet TTB requirements.

Getting your alcohol labels right

The TTB’s rules look intimidating from the outside, but they come down to a predictable set of elements, a fixed warning, and a COLA. Get those right and most of the risk goes away. Where it gets practical is the print itself, making sure the warning is the right size, the elements sit together, and the printed label matches the one the TTB approved.

That’s the part we can help with. We print wine, spirits, and beer labels for brands across the country and know where these requirements live on a real label. Request a sample pack to see our materials and finishes, or get in touch and we’ll help you get a print-ready, compliant label out the door.

Frequently asked questions

What does TTB stand for?

TTB stands for the Alcohol and Tobacco Tax and Trade Bureau, a bureau of the U.S. Department of the Treasury. It regulates the labeling, advertising, and taxation of distilled spirits, wine, and malt beverages sold in the United States.

What are the mandatory elements on a TTB alcohol label?

The core mandatory elements are the brand name, class and type, alcohol content (ABV), net contents, the name and address of the bottler or importer, and the Government Warning statement. Depending on the product, you may also need country of origin, state of distillation, a sulfite declaration, age statements, and other conditional disclosures. Most elements must appear together in a single field of vision.

What is the exact TTB Government Warning statement?

The fixed text is: “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 wording cannot be changed, the words “GOVERNMENT WARNING” must be in bold capital letters, and there are minimum type sizes based on container size.

Do I need a COLA to sell alcohol?

Most alcohol beverages need a Certificate of Label Approval (COLA) from the TTB before they can be sold or shipped in interstate commerce. You submit your label through the TTB’s COLAs Online system, and the TTB reviews it against the rules for your product before issuing an approval or a rejection.

Is my beverage regulated by the TTB or the FDA?

The TTB regulates distilled spirits, wine at 7% ABV or above, and malt beverages made with malted barley and hops. The FDA regulates wine below 7% ABV and beers made without malted barley or hops, which follow FDA food-labeling rules including a Nutrition Facts panel and ingredient list. Which agency applies determines which labeling rules you follow.

What changed in the 2020 TTB final rule?

The April 2020 final rule modernized the labeling and advertising regulations. Key changes: mandatory information can now sit anywhere within a single field of vision, personalized labels were formalized so customizations can change without a new COLA, agave spirits were recognized as a class, the vodka standard was loosened, age-statement rules were relaxed, and the distilled-spirits alcohol content tolerance was set at plus or minus 0.3 percentage points.

Why do TTB labels get rejected?

Most COLA rejections come from small label details: a missing mandatory element, a Government Warning that is too small, not bold, or low-contrast, an alcohol content outside tolerance, or a class-and-type statement that doesn’t match the standard of identity. These are usually cheaper to catch before submitting the label than after a rejection.

Ready to print a compliant alcohol label?

If you’re getting a wine, spirits, or beer label ready for the TTB, we can help you land the mandatory elements, the Government Warning, and the type sizes in a print-ready file. Request a sample pack to see our materials, or get in touch and we’ll help you get it right before it goes to print.

More on alcohol labeling and compliance:

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TTB Beer Label Requirements: 8 Elements You Need on Craft Beer Labels

A great craft beer label has to do two jobs at once. It has to catch a shopper’s eye on a crowded shelf, and it has to satisfy the Alcohol and Tobacco Tax and Trade Bureau (the TTB) before you can legally sell it. Miss a required element and your label approval can get rejected, which means a delay right when you’re trying to get a beer to market.

Here are the 8 elements the TTB requires on a malt beverage (beer) label, what each one actually means, and where the rules live so you can check them yourself.

The 8 required elements at a glance:

Brand name
Class and type designation
Name and address of the brewer, bottler, or importer
Net contents
Alcohol content (when required)
Ingredient and additive disclosures (when they apply)
The Government Warning
Country of origin (imported beer only)

All of this lives in 27 CFR 7.63, the section that lists the mandatory information for a malt beverage label, plus the sections that spell out each element. The TTB modernized these rules in 2022, so if you’ve seen older guides citing section numbers in the 7.20s, those have moved.

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First, the ground rules: legibility and placement

Before the individual elements, two general rules apply to all of the mandatory information:

It has to be readable. Mandatory information must be readily legible under ordinary conditions and set against a contrasting background (27 CFR 7.52).
It has to be big enough. The minimum type size is 2 mm for containers larger than half a pint, and 1 mm for containers of half a pint or less (27 CFR 7.53). The information also can’t be covered or hidden (27 CFR 7.54).

Keep these in mind early, because they affect how much room your design needs to leave for the required copy.

1. Brand name

Every label needs a brand name, the name the beer is marketed and sold under (27 CFR 7.64). It can’t mislead people about the age, origin, identity, or other characteristics of the beer. If a product isn’t sold under a brand name, the name of the bottler or importer stands in as the brand name.

2. Class and type designation

This is the part of the label that tells people what the product actually is. It can be as general as “malt beverage” or as specific as a recognized style. The rules for class and type live in Subpart I of Part 7 (sections 7.141 through 7.147), and Chapter 4 of the TTB’s Beverage Alcohol Manual is the practical guide to the designations.

Worth knowing: Your style name in the artwork (say, “Hazy IPA”) and your official class designation are two different things. The artwork can read however your brand wants. The class designation just has to be a recognized one, shown clearly on the label.

A trio of beer bottle labels with net contents and other TTB label requirements.

3. Name and address

The label has to identify who’s responsible for the beer, with wording that depends on where it was made:

Brewed in the U.S.: phrases like “Brewed by” or “Brewed and bottled by,” followed by the brewer’s name and address (27 CFR 7.66).
Imported: “Imported by” (or similar), followed by the importer’s name and address (27 CFR 7.68).

The name has to match your brewer’s notice or basic permit on file with the TTB. Small mismatches here are a common reason a label gets kicked back.

4. Net contents

The label has to state how much beer is in the container, in U.S. customary units like fluid ounces, pints, or quarts (27 CFR 7.70). Metric measures are allowed in addition to the U.S. units, but not in place of them. Net contents can be printed on the label or molded into the container itself.

5. Alcohol content (when required)

Here’s one that surprises a lot of brewers: for beer, federal rules make alcohol content optional, unless your state requires it (or in a few cases prohibits it). Alcohol content “may be stated on any malt beverage label, unless prohibited by State law” (27 CFR 7.65). Most brewers include it anyway because customers expect it.

If you do state it, the TTB allows a tolerance of 0.3 percentage points above or below the listed number for beers at 0.5% ABV or higher, and it has to be expressed as a percentage by volume.

Heads up, this may change: The TTB has a 2025 proposal (Notice 237) that would make an alcohol content statement mandatory for more products, as part of a broader “Alcohol Facts” panel. It’s still a proposal, not law (more on that below), but it’s worth knowing the optional status may not last.

A beer can with a prominent government warning.

6. Ingredient and additive disclosures (when they apply)

Beer labels don’t carry a full ingredient list, but a few specific additives have to be declared when they’re present (27 CFR 7.63(b)):

FD&C Yellow No. 5: a statement such as “Contains FD&C Yellow No. 5.”
Sulfites: “Contains sulfites” (or “Contains a sulfiting agent”) when the beer has 10 or more parts per million of sulfur dioxide.
Aspartame: the statement “PHENYLKETONURICS: CONTAINS PHENYLALANINE,” in capital letters, set apart from other text.
Cochineal extract or carmine: a statement naming the additive, such as “Contains cochineal extract” or “Contains carmine.”

Worth knowing: Older label guides (and a lot of pages still floating around online) list a required saccharin warning about cancer in lab animals. That requirement was removed from the TTB regulations back in 2004 and is no longer part of beer labeling. If you’re working from an old checklist, drop it.

7. The Government Warning

Every beer at 0.5% ABV or higher needs the federal Government Warning, set in 27 CFR 16.21. It has to read, word for word:

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.

“GOVERNMENT WARNING” appears in bold capital letters, and the rest of the text is fixed. It has to run as a single continuous paragraph and can sit on the front, side, or back of the container. You can’t paraphrase or shorten it.

8. Country of origin (imported beer only)

This one applies only to imported beer (27 CFR 7.69). The label has to show where the beer came from, commonly as “Product of [country].” The TTB rule points to U.S. Customs and Border Protection for the exact marking formats, so importers should check those as well. Domestic beer doesn’t need a country-of-origin statement.

How label approval works: the COLA

Once your label has all of its required elements, most beers need a Certificate of Label Approval (a COLA) before you can sell across state lines. You apply with TTB Form 5100.31 through the TTB’s COLAs Online system, and the process is governed by 27 CFR Part 13. The TTB reviews your artwork against the requirements above and either approves it or sends it back with the issues to fix.

The fastest way to avoid a rejection is to get the required elements right the first time, since a kicked-back label usually means weeks of delay.

What’s changing in 2025 and beyond

The 8 elements above are current. But the TTB has proposed the biggest change to alcohol labeling in years. In January 2025 it published two proposed rules, laid out in its announcement on Alcohol Facts and allergen labeling:

A mandatory “Alcohol Facts” panel (serving size, servings per container, alcohol by volume, calories, carbohydrates, fat, and protein), which would also make an alcohol content statement mandatory for more products.
Mandatory major food allergen labeling (milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans, and sesame).

Both are still proposals, not law. The comment period closed in August 2025, and if a final rule is published, the TTB has proposed giving the industry five years to comply. Nothing on your label has to change today, but it’s worth designing with a little room to grow.

Quick pre-print checklist:

☐ Brand name (not misleading)
☐ Class and type designation
☐ Name and address (matches your TTB permit)
☐ Net contents in U.S. units
☐ Alcohol content (if your state requires it, or you choose to include it)
☐ Any required additive disclosures (FD&C Yellow No. 5, sulfites, aspartame, cochineal/carmine)
☐ Government Warning, word for word
☐ Country of origin (imported beer only)
☐ Type size and legibility check (2 mm / 1 mm)
☐ COLA approved before you sell across state lines

Getting all of this onto a label that still looks great is what we do. If you’re working on a new can or bottle, take a look at our craft beer label options, or send us your artwork and we’ll help you make sure it has everything the TTB expects.

Frequently asked questions

What are the required elements on a craft beer label?

The TTB requires a brand name, a class and type designation, the name and address of the brewer or importer, net contents, alcohol content (when required), certain ingredient and additive disclosures, the Government Warning, and, for imported beer, country of origin. These are set in 27 CFR 7.63 and the related sections of Part 7.

Is alcohol content required on a beer label?

Under federal rules, alcohol content is optional for beer unless your state requires it (or, in limited cases, prohibits it). Most brewers list it anyway. A 2025 TTB proposal would make it mandatory for more products, but that rule is not final.

Do craft beer labels need a Nutrition Facts or ingredient list?

No. Beer regulated by the TTB doesn’t require a Nutrition Facts panel or a full ingredient list today, though specific additives like sulfites or FD&C Yellow No. 5 must be declared. A 2025 TTB proposal would add a mandatory “Alcohol Facts” panel and allergen labeling, but it has not been finalized.

What is a COLA and do I need one?

A COLA is a Certificate of Label Approval. Most beers sold across state lines need one before they can go to market. You apply with TTB Form 5100.31 through COLAs Online, and the TTB reviews your label against the required elements.

Does a beer label still need a saccharin warning?

No. The saccharin warning that used to be required was removed from the TTB regulations in 2004. If you’re using an old checklist that still lists it, you can drop it.

Where does the Government Warning have to go on the label?

It can appear on the front, side, or back of the container, but it has to run as a single continuous paragraph, with “GOVERNMENT WARNING” in bold capital letters, using the exact wording in 27 CFR 16.21.

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Why Don’t Beer, Wine, and Spirits Labels Have to Disclose Ingredients or Serving Facts on Labels?

⚞ The Highlights:

- Different agency, different rules. Beer, wine, and spirits labels are regulated by the TTB (the Alcohol and Tobacco Tax and Trade Bureau) under the Federal Alcohol Administration Act, not by the FDA under food labeling law. That’s why the FDA’s Nutrition Facts and ingredient-list rules don’t apply.
- Ingredients and serving facts are voluntary today. You can add them, and many brands do, but federal rules don’t require them on most alcohol.
- Some “alcohol” actually falls under the FDA. Beers not made from malted barley and hops, and wines under 7% alcohol by volume, are regulated by the FDA and do need a Nutrition Facts panel and an ingredient list.
- This may change. In January 2025 the TTB proposed two rules that would make an “Alcohol Facts” statement and major food allergen labeling mandatory. They are still proposals, not law.

Pick up a box of crackers and you’ll find a Nutrition Facts panel and a full ingredient list. Pick up a six-pack, a bottle of wine, or a fifth of bourbon, and most of that information isn’t there. If you make or sell alcohol, you’ve probably wondered why your label gets to skip what every packaged food has to show.

The short answer: your label answers to a different agency, under a different law. Here’s how that works, what your label actually has to include today, and the proposed rules that could change all of it in the next few years.

(more…)

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Dos and Don’ts for Non-Alcoholic Beer Labels

⚞ The Highlights:

“Non-alcoholic” and “alcohol-free” aren’t interchangeable. “Non-alcoholic” means under 0.5% alcohol by volume and has to carry a specific disclaimer. “Alcohol-free” means 0.0%, with no wiggle room.
A product under 0.5% can’t be called “beer.” It has to be a “malt beverage,” “cereal beverage,” or “near beer.”
Who regulates your label depends on ingredients. Made from malted barley and hops? It’s a TTB malt beverage. Made without them? It falls under the FDA and needs a Nutrition Facts panel and ingredient list.
The Government Warning usually doesn’t apply. A true non-alcoholic product under 0.5% is outside the rule that requires it.

Do: get the “non-alcoholic” vs. “alcohol-free” distinction right

These two phrases mean different things, and the TTB treats them differently.

“Non-alcoholic” can be used on a malt beverage only if the statement “contains less than 0.5 percent (or .5%) alcohol by volume” appears immediately next to it, in legible print on a contrasting background. This is set in 27 CFR 7.65(e).
“Alcohol-free” can be used only on a product that contains no alcohol at all (0.0%). There’s no tolerance, per 27 CFR 7.65(f).

That second one carries an extra step. Because “alcohol-free” promises 0.0%, the TTB requires formula approval with laboratory sample analysis to back up the claim before it will approve the label. That’s spelled out in TTB Guidance G 2016-1A. If your product has any trace of alcohol, call it “non-alcoholic,” not “alcohol-free.”

Don’t: call a sub-0.5% product “beer,” “ale,” or “lager”

The TTB reserves “beer” and its cousins for products at 0.5% alcohol by volume or higher. A product under that line can’t use “beer,” “lager,” “ale,” “porter,” “stout,” “malt liquor,” or any other designation normally used for full-strength beer. Instead, it has to carry one of three class designations: “malt beverage,” “cereal beverage,” or “near beer.” This is in 27 CFR 7.145.

You can still build your brand around the beer experience in your design and marketing. The class designation just has to be one of those three terms, shown clearly on the label.

A bunch of non alcoholic malt beverage labels on cans.

Worth knowing: This is one of the most common mix-ups we see on non-alcoholic labels. A brand will design a gorgeous “NA IPA” can and use “IPA” as the class designation. The art can say whatever fits your brand, but the official class designation on the label needs to be “malt beverage,” “cereal beverage,” or “near beer.”

Do: figure out who regulates your label first, the TTB or the FDA

This is the question that trips up the most NA brands, and it’s worth answering before you design anything. Whether your label follows TTB rules or FDA rules comes down to how the product is made, not just its alcohol content.

Made from malted barley and hops (then brewed and dealcoholized): it’s a malt beverage under the Federal Alcohol Administration Act, so it stays under the TTB, the same as regular beer, even at 0.0% to 0.5%. The FDA confirms this in its guidance on dealcoholized malt beverages: these stay with the TTB “regardless of alcohol content.”
Made without malted barley and hops (for example, brewed from other grains, or without hops): it doesn’t meet the malt beverage definition, so it falls under the FDA. That means it needs a full Nutrition Facts panel and ingredient list under FDA food labeling rules, per the FDA’s guidance on labeling certain beers.

So two non-alcoholic “beers” sitting next to each other on a shelf can follow completely different labeling rules. If you’re not sure which side of the line your recipe falls on, confirm it before you print. (For the bigger-picture version of why alcohol and food labels diverge, see our post on why beer, wine, and spirits labels don’t have to disclose ingredients.)

Creative can labels for non alcoholic beers.

NA beer vs. regular beer: what each label needs

Here’s a side-by-side of the labeling differences, assuming your non-alcoholic product is a traditionally brewed malt beverage under the TTB.

Label element	Regular beer (0.5% ABV or higher)	Non-alcoholic (under 0.5% ABV)
Class designation	“Beer,” “ale,” “lager,” “IPA,” etc.	“Malt beverage,” “cereal beverage,” or “near beer” only
“Non-alcoholic” statement	Not applicable	If “non-alcoholic” is used, must add “contains less than 0.5% alcohol by volume” adjacent to it
Government Warning	Required	Not required (product is under 0.5% ABV)
Brand name, net contents, name and address	Required	Required
Nutrition Facts panel	Not required (Serving Facts optional)	Not required if it’s a TTB malt beverage; required if the product falls under the FDA
TTB label approval (COLA)	Required for a malt beverage	Required for a TTB malt beverage; “alcohol-free” (0.0%) also needs lab analysis

Do: know when the Government Warning applies, and when it doesn’t

The federal Government Warning is required on alcoholic beverages, which the rules define as products containing 0.5% alcohol by volume or more (27 CFR 16.10). A genuine non-alcoholic product under 0.5% falls outside that definition, so it generally doesn’t need the warning.

One caution: this is one of the few places where being just over the line matters a lot. If your product comes in at 0.5% or above, even slightly, it’s an alcoholic beverage in the eyes of the rule and needs the full Government Warning. Know your actual alcohol content before you decide.

Don’t: forget the tax marking on a true cereal beverage

If your product is a cereal beverage (a malt product under 0.5% that the brewer removes without paying beer tax), the bottle label has to carry the legend “Nontaxable under section 5051 I.R.C.” This sits in the brewery tax rules at 27 CFR 25.242, not in the main labeling part, so it’s easy to miss. It’s a small line, but leaving it off a cereal beverage label is a compliance gap.

Don’t: let the rules flatten your design

Non-alcoholic beer is a crowded, fast-growing category, and the label still has to earn the sale. Shoppers reaching for an NA option are often trying something new, and the can is what gets them to pick it up. The compliance pieces (class designation, the “non-alcoholic” line, any required panels) can all live cleanly on a well-planned layout without dulling the design.

This is where we come in. Whether your NA product is a TTB malt beverage or an FDA-regulated beverage, we’ll help you fit everything the label needs into artwork that still looks the way you want it to. Take a look at our craft beer label options, or reach out and we’ll talk through your project.

Frequently asked questions

Is non-alcoholic beer regulated by the TTB or the FDA?

It depends on how it’s made. A non-alcoholic beer brewed from malted barley and hops (then dealcoholized) is a malt beverage regulated by the TTB, the same as regular beer. A product made without malted barley and hops falls under the FDA and follows food labeling rules, which include a Nutrition Facts panel and ingredient list.

What’s the difference between “non-alcoholic” and “alcohol-free”?

“Non-alcoholic” means the product contains less than 0.5% alcohol by volume, and the label has to say “contains less than 0.5% alcohol by volume” next to the claim. “Alcohol-free” means exactly 0.0% alcohol, with no tolerance, and the TTB requires lab analysis to support that claim before approving the label.

Can you call a non-alcoholic product “beer”?

No. A product under 0.5% alcohol by volume can’t use “beer,” “ale,” “lager,” “porter,” “stout,” or similar terms as its class designation. It has to be labeled a “malt beverage,” “cereal beverage,” or “near beer.” Your branding and artwork can still center on the beer experience.

Do non-alcoholic beers need the Government Warning?

Usually not. The federal Government Warning is required on beverages with 0.5% alcohol by volume or more. A true non-alcoholic product under 0.5% falls outside that requirement. If your product is 0.5% or above, the warning is required.

Do non-alcoholic beers need a Nutrition Facts panel?

Only if the product is regulated by the FDA rather than the TTB. Traditionally brewed NA malt beverages (malted barley and hops) stay under the TTB and don’t require one, though some brands add a nutrition or Serving Facts panel voluntarily. Products made without malted barley and hops fall under the FDA and do need a Nutrition Facts panel and ingredient list.

Does a non-alcoholic beer need TTB label approval?

If it’s a TTB malt beverage, yes, it generally needs a Certificate of Label Approval (COLA) like any other malt beverage. An “alcohol-free” (0.0%) product also needs formula approval with laboratory analysis. FDA-regulated products don’t get a COLA, but they have to meet FDA food labeling rules.

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Anatomy of a Wine Label

⚞ The Highlights:

U.S. wine labels are regulated by the Alcohol and Tobacco Tax and Trade Bureau (TTB). Required elements include the brand name, class or type designation, alcohol content, net contents, producer and bottler info, the sulfite warning (if applicable), and the federal government warning.
Most required information has flexibility on placement: brand label (front) vs. back label vs. either. The brand name and class/type must be on the brand label; everything else can usually live on the back.
Vintage year, appellation, and varietal are technically optional but trigger specific rules when included (75% varietal threshold, 75–85% appellation thresholds, etc.).
Material choice (paper, BOPP, soft-touch laminate, foil) sets the visual and tactile tone of the bottle as much as the design itself.

Wine labels carry more rules than most product labels because the TTB regulates them under the Alcohol and Tobacco Tax and Trade Bureau’s labeling requirements. The good news: the rules have been stable for years, and once you know what’s mandatory and what’s flexible, designing a compliant label gets straightforward. Below is what every U.S. wine label needs, where it can go, and what to think about for materials and design.

What goes on the front vs. the back of a wine label?

The TTB doesn’t strictly dictate which side of the bottle gets each piece of information. Some elements must appear on the “brand label” (typically the front), but most can go on either label. Here’s how it usually breaks down.

Element	Where it can go	Required?
Brand name	Brand label (front)	Yes
Class or type designation (varietal name, “red wine,” “table wine,” etc.)	Brand label (front)	Yes
Alcohol by volume (ABV)	Either label	Yes (some classes deduce it from designation)
Net contents	Either label, OR blown/etched into the bottle	Yes
Producer / bottler name and address	Either label	Yes
Sulfite warning	Either label	Required if >10 ppm SO₂
Government health warning	Either label (typically back)	Yes
Vintage year	Either label	Optional (with rules if claimed)
Appellation / region	Either label	Optional (with grape-source thresholds if claimed)
Pairing notes, flavor profile, story	Back label (typical)	No

What Information is Included on Wine Labels?

Below is each element in detail, with the rules that apply. What needs to be included on a wine bottle label?

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Brand name

Who made the wine? The winery’s branding usually appears at the top or bottom of the brand label, depending on the design tradition you’re working in (French wines often place the winery prominently at the top; New World wines vary).

Fanciful name

What’s this specific wine called? A fanciful name is a secondary name used to differentiate brands within the same winery. Brengman Brothers’ “Runaway Hen” is one example. Fanciful names are optional, but they don’t replace the need for a class and type designation. When you use one, the TTB requires an additional tax class on the label based on alcohol percentage. For example: “red table wine” or “white table wine” for wines under 14 percent alcohol; “red wine” or “white wine” for wines above 14 percent.

Vintage (year)

When were the grapes harvested? Vintage information isn’t mandatory, but it’s common because it speaks to the quality of the bottle’s contents. Especially if you’re paying attention to year-to-year variation. If you list a vintage, federal rules require that 95% of the wine come from grapes harvested that year (85% for wines from a state or county appellation).

Wine or varietal type

What kind of wine is in the bottle? This is where the grape or varietal type is communicated: Sauvignon Blanc, Pinot Noir, Cabernet Sauvignon, etc. Listing a class or type is required. If you call out a specific varietal name, at least 75 percent of the wine must come from that grape variety. Otherwise, the label needs a generic class designation like “red wine,” “white wine,” or “table wine.”

Appellation (region)

Where was the wine made? Region of origin breaks down differently depending on what you’re claiming:

State or county appellation: at least 75 percent of grapes must come from that location (federal rule).
American Viticultural Area (AVA, e.g., Napa Valley): at least 85 percent of grapes must come from that AVA.
State-specific rules: some states have stricter requirements. California, for example, mandates that 100 percent of grapes come from California if the state name is on the bottle.

Producer and bottler

Where was the wine made and bottled? If the bottling location differs from the winery or vineyard, both names and addresses must appear on the label.

Alcohol content

What’s the percentage of alcohol by volume (ABV)? Required on every label unless it can be deduced from the class designation (table wine implies 14 percent or less). Best practice is to print the ABV explicitly anyway, because consumers and retailers expect to see it.

Net contents

How much wine is in the bottle? Net contents (in milliliters) must appear on every bottle, either printed on the label or blown/etched into the glass.

Sulfite warning

If the wine contains 10 parts per million or more of sulfur dioxide, the label must say “CONTAINS SULFITES” in clear, legible type. Most wines have natural sulfites at levels above 10 ppm, so this warning appears on the vast majority of bottles.

Government warning

Under the Alcoholic Beverage Labeling Act of 1988, every alcoholic beverage label must carry a specific government health warning. The TTB-mandated text reads:

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.

This warning typically lives on the back label. It must be set off from other information and printed in legible type that meets TTB minimum size requirements.

Optional back label content

Beyond the regulatory elements, back labels often include pairing suggestions, flavor notes, and a short story about the winery or vineyard. None of this is required, but it’s the part of the label where consumers actually engage with your brand. Use it.

A TTB compliant wine label featuring necessary legal information.

Wine label materials: choosing the right look and feel

Materials and finishes set the tone of the bottle as much as the design does. Wine is a category where consumers pick up the bottle and feel it before deciding to buy, so the tactile choice matters.

Paper stocks

Smooth white paper: clean, modern look. Works for contemporary brands and design-forward labels.
Textured papers (felt, cotton, linen): vintage and artisanal feel. Common for premium reds, family wineries, and boutique labels.
Estate or rag papers: high-end, hand-feel paper that signals serious craft. Often used for reserve and library wines.
Kraft or unbleached paper: earthy, organic, sustainable positioning. Good fit for organic, biodynamic, or natural wines.

Film stocks

BOPP / polypropylene: waterproof and durable, works well for wines that will live in damp cellars or ice buckets. Doesn’t have the hand-feel of paper but holds up better.
Clear film: makes the design appear printed directly on the bottle. Common for premium and minimalist label designs.

Finishes and special treatments

Matte vs. gloss varnish: matte reads understated and premium; gloss reads bright and vibrant. Most premium wines lean matte.
Soft-touch laminate: velvety hand-feel that’s increasingly common in luxury wines and spirits.
Hot foil stamping: gold, silver, copper, or holographic foil for logos, brand names, or borders. The signature look for premium positioning.
Embossing or debossing: raised or recessed elements that add tactile dimension. Often paired with foil for a layered effect.
Spot UV varnish: selective glossy coating that highlights specific design elements (logo, illustration) against a matte background.
Wet-strength laminate: for wines that will sit in ice buckets or damp cellars, an extra moisture-resistant coating prevents the label from bubbling, peeling, or fading.

The right combination depends on the wine and the brand. Sample packs are the fastest way to feel the difference between paper textures and finishes before committing to a run.

Wine label gallery

Wine bottle design considerations

Wine bottles come in standard shapes (Bordeaux, Burgundy, Champagne, Hock) plus custom or asymmetrical bottles. Each shape needs a label that fits its curve and proportions. Practical design rules:

Match the label to the bottle’s flat zone. The label should sit on a section of the bottle that’s relatively flat, not on the steepest part of a shoulder or neck.
Mirror or contrast the bottle silhouette. Some labels echo the bottle shape (rectangular labels on Bordeaux); others create deliberate visual tension (a circular label on a rectangular bottle).
Plan for the front-back relationship. If the front is minimal, the back can carry more story. If the front is detailed, keep the back focused on regulatory copy and a tight description.
Consider the cellar. Wines stored on their sides for years are exposed to humidity and condensation. Choose materials that can survive that environment.

For artwork files, send Adobe Illustrator files or high-resolution PDFs whenever possible. They preserve typography, vectors, and layer structure so we can verify dimensions and produce a clean proof before printing.

Wine bottle shapes Frequently asked questions

What information is required on a wine bottle label?

U.S. wine labels are regulated by the TTB and must include: brand name, class or type designation (varietal name or generic like “red wine”), alcohol by volume, net contents, producer and bottler name and address, the sulfite warning (if SO₂ is over 10 ppm, which most wines are), and the federal government health warning. Vintage year, appellation, and fanciful names are optional but trigger specific rules when included.

What does TTB stand for and what does it regulate?

TTB stands for the Alcohol and Tobacco Tax and Trade Bureau. It’s the federal agency that regulates labeling, advertising, and trade practices for wine, spirits, and beer in the United States. Wine labels must receive a Certificate of Label Approval (COLA) from the TTB before the wine can be sold across state lines.

Does my wine label need a vintage year?

No, vintage year is optional. But if you list one, federal rules require that 95% of the wine come from grapes harvested that year (85% for wines from a state or county appellation). Many premium and varietal wines list a vintage anyway because consumers expect it for that category.

What’s the difference between a varietal wine and a table wine?

A varietal wine names a specific grape (Cabernet Sauvignon, Pinot Noir, Sauvignon Blanc) and must contain at least 75% of that grape variety. A table wine uses a generic designation (“red wine,” “white wine,” “red table wine”) when the wine doesn’t meet the 75% varietal threshold or when the producer chooses not to claim a specific grape. Both need to list a class designation; varietal is just more specific.

What’s an AVA and when do I need to list one?

An AVA (American Viticultural Area) is a federally designated grape-growing region. Napa Valley, Willamette Valley, Russian River Valley are examples. Listing an AVA on a wine label is optional, but if you do, at least 85% of the grapes must come from that AVA. Some states (California, for example) have stricter rules that require 100% of grapes to come from the state if the state name is on the label.

Why do wine labels say “Contains Sulfites”?

If a wine contains 10 parts per million or more of sulfur dioxide (SO₂), the TTB requires the label to display “CONTAINS SULFITES” in clear, legible type. Sulfites occur naturally in wine fermentation and are commonly added as preservatives, so the warning appears on the vast majority of commercially produced wines.

Where does the government warning go on a wine label?

The federal government health warning required by the Alcoholic Beverage Labeling Act of 1988 can go on either the front (brand) label or the back label, but most wineries place it on the back label so it doesn’t crowd the brand-side design. The warning must be set off from other information and printed in legible type that meets TTB minimum size requirements.

Do I need both a front and back label on a wine bottle?

Not strictly. The TTB requires certain mandatory information (brand name, class designation, ABV, net contents, producer/bottler, government warning, sulfite warning) but doesn’t dictate that it be split across two labels. Some wineries use a single wrap-around label that covers both sides. Two-label designs (front + back) are more common because they let the front carry brand and the back carry regulatory copy and storytelling.

Make your wine labels stand out

Once the regulatory pieces are in place, the materials, finishes, and design choices are what set the bottle apart on the shelf. We work with wineries on the full range of label types. Paper to film, matte to soft-touch, foil to embossing. And we’ll help you sort through which combination fits the wine.

If you’re ready to talk through a project, take a look at our wine label printing page for an overview of materials and finishes, or request a sample pack to feel the paper, film, and finish options in person. Our facility offers fast processing. Five business days from artwork approval to ship. With no minimums and an expert review on every project before anything goes to press. Get in touch when you’re ready.

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How to Choose the Right Packaging for Alcohol Shipping: Safety, Compliance, and Branding

Whether you’re a small business looking to send out your craft spirits or a large brand aiming to distribute widely, making sure your products reach their destination safely and legally is crucial. Shipping alcohol can be a complex process filled with numerous regulations and requirements that vary significantly from state to state.

This guide will break down the essentials of alcohol shipping regulations, including the necessary permits, packaging for shipping alcohol techniques, and state-specific guidelines that you need to follow.

Regulatory Compliance

Before arranging any shipment of alcohol, you should be aware of each state’s transportation regulations.

Shippers should also obtain the necessary licenses and establish agreements with carriers such as FedEx and UPS. Each state may have its own specific regulations regarding the shipment of alcohol. However, some states completely prohibit it.

Some licenses that are required include:

Federal Basic Permit: Issued by the Alcohol and Tobacco Tax and Trade Bureau (TTB), this permit is necessary for any business engaging in the production, importation, or wholesale distribution of alcohol.
State Alcohol Shipping Permit: Each state requires shippers to obtain an alcohol shipping permit. The necessary type of permit varies by state, and some states may require multiple permits depending on the nature of the shipment.
Carrier Agreements: Agreements with carriers like FedEx, UPS, and DHL that outline the terms and conditions for shipping alcohol.
Sales Tax Permit: Required by most states to legally collect sales tax on shipped alcohol.
Shipping Carrier Compliance Bond: A bond that some carriers require to ensure compliance with their alcohol shipping guidelines and regulations.

Adult Signature Verification

All alcohol shipments require an adult signature (21+ years) upon delivery. Alcohol Signature Verification ensures that alcohol is not delivered to minors and typically incurs an additional fee. Carriers have specific procedures to verify the recipient’s age and identity at the time of delivery.

These procedures often include checking a valid government-issued identification and obtaining a signature to confirm that someone of legal drinking age received the package.

Safety and Durability

After checking with federal and state laws, your next priority is to get your customer a safe and intact product. Proper packaging helps your products withstand transit shocks, vibrations, and potential impacts.

These are a few best practices for getting your alcoholic beverage delivered in mint condition:

Use the right materials: Choose a durable box with inner packaging made of polystyrene, molded pulp, or die-cut corrugated.
Protection: Inside the box, each bottle should be individually cushioned with padded dividers or foam inserts to prevent movement and breakage. To protect bottles, you can also use bubble wrap or wine bottle sleeves.
Pack tightly: Fill any empty space with filler material like foam peanuts, air pillows, or crumpled paper. Wrap each bottle individually to prevent them from breaking. Pack the box so that it doesn’t move when shaken.
Secure the package: Use strong tape to seal the box along all edges and corners. You can also reinforce the bottom with extra tape or a corrugated pad.
Label instructions: Mark the box as “Fragile” or “Handle with Care”.
Seasonal considerations: Temperature control is another consideration—using insulated packaging or gel packs can help maintain the beverage’s quality, especially during extreme weather conditions.

Packaging and Branding Materials

Picture this: your beautifully crafted product travels thousands of miles, enduring various handling stages and environmental conditions, only to arrive with a worn-out, unreadable label.

Using the proper packaging materials will help your alcohol shipments reach your customers in their best condition. Below are a few important considerations to keep in mind when shipping alcohol.

Materials

Using acceptable materials like molded polystyrene, pulp dividers, and sturdy corrugated cartons ensures your product and its packaging remain intact. When it comes to a safety net, reinforced bottoms are your best friend.

Most major carriers, like FedEx and UPS, include detailed guidelines on what materials can be used for packaging on their websites.

Strong adhesives

Whether braving downpours or UV rays from the sun, a label with strong adhesive should stay put. The right adhesive helps your label stay put and in compliance no matter what wild adventures it may encounter.

Label laminates

Laminates act as barriers against environmental factors, protecting labels from moisture, temperature changes, and abrasion. High-quality laminates keep crucial information like legal disclaimers, barcodes, and brand details intact and readable during transit.

UV coatings

UV coatings provide a layer of protection against harmful ultraviolet light, which can degrade both the label material and the printed information over time. By applying UV coatings, labels are protected against fading, discoloration, and other forms of deterioration caused by UV exposure, particularly during extended periods in transit or storage.

Alcohol Label Requirements

Preparing your label before it gets picked up by your carrier helps avoid issues during shipping. Here is what you need to know:

Electronic shipping solutions: Shippers must use carrier-approved electronic shipping solutions to create and manage shipping labels. This allows shipments to be properly documented and traceable.
Active alcohol shipping account: Carriers like FedEx and UPS have specific systems for processing alcohol shipments. For instance, FedEx requires shippers to have an active alcohol shipping account and a signed agreement.
Special labels: A special alcohol label and an adult signature requirement sticker. Similarly, UPS mandates that shippers have a UPS Agreement for Approved Beer or Wine Shippers.
Declaration: You’ll need to provide details about the contents of the package with clear identification. Alcohol shipments must be clearly labeled as containing alcohol.
Adult signature: Labels should indicate that an adult signature is required upon delivery.
Compliance with origin and destination regulations: Special labels can be obtained from the shipping carrier, and packages must comply with both origin and destination state labeling requirements.

Direct-to-Consumer Alcohol Packaging vs. Distribution Packaging

As an alcohol manufacturer, you might be wondering about the differences between direct-to-consumer alcohol packaging and packaging designed for distribution and shipping on a larger scale.

When shipping directly to consumers, packaging needs to cater to a more personal experience—think appealing designs that embody your brand and provide an unboxing experience. Consider how your packaging can spark joy, but be tough enough to handle.

On the other hand, B2B or distribution packaging focuses more on efficiency and durability; your primary goal is to ensure products arrive intact and ready for resale. This often means using more robust supplemental materials and prioritizing functionality over aesthetics.

Both packaging types have one thing in common—they require a focus on product protection. If you choose the right packaging partner, both can look good and maintain the integrity of your product.

Let Blue Label Help You Choose the Right Packaging

Blue Label Packaging Co. has dedicated experts who can guide you through the ins and outs of packaging regulations. We offer customized solutions like alcohol-compliant labels with no minimum order, second-skin shrink sleeves, and hang tags with luxe finishes.

At Blue Label Packaging, we put our expertise to work. Explore our product labels or talk to an expert about your next packaging product.

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Hard Cider Label Requirements: Breaking Down TTB Meaning and FDA Regulations

There is a lot more to hard cider labels than your brand and an eye-catching design. Hard cider labeling regulations are not only complicated, but can also vary depending on the strength of your product. Let’s break down the different hard cider label requirements you need to know for your drinks.

Who Regulates Hard Cider Labeling?

It’s essential to follow regulations when labeling hard cider. The tricky part is that it’s not always clear which rules you need to follow.

While you might put hard cider on draught, it isn’t classified as a type of beer. Hard cider is traditionally defined by the TTB as “wine fermented from apples, including apple juice or apple concentrate.” However, the TTB broadened the criteria for hard cider in 2017. These changes expanded the definition to meet the following requirements.

Hard cider should be less than (not equal to) 8.5 percent alcohol by volume (abv), up from 7 percent.
Hard cider should have a maximum allowable carbonation level of 0.64 grams of carbon dioxide per hundred milliliters of wine, up from 0.392.
Hard cider is now allowed to use pears and pear juice concentrate and still receive the hard cider tax rate.

Of course, these changes also impact which governing body oversees different hard ciders. Ciders with an abv under 7 percent are regulated by the Food and Drug Administration (FDA). The remaining hard ciders at or above 7 percent are in turn regulated by the TTB.

A six pack of cans following hard cider label requirements from the TTB.

Hard Cider Label Regulations: What You Need to Include

As you may expect, both the FDA and TTB require a lot of information on their labels. While there are many overlapping regulations, there are some notable differences between hard cider label requirements from the FDA and TTB. The following elements are mandatory pieces of information that are required by the FDA, the TTB, or both organizations.

Brand name
Name and address of the bottler
Class, type or other designation
Net contents
Alcohol content
Ingredient, nutrition, and allergen listings
Government Health Warning
Various declarations

These elements also have specific requirements for how they’re presented as well. Aside from the alcohol content statement and government health warning, all mandatory information uses the following guidelines for minimum type size.

If the container size is 187 milliliters or less, type must be at least 1 millimeter.
If the container size is more than 187 milliliters, type must be at least 2 millimeters.

Brand name (FDA and TTB)

The brand name is defined as the name under which you sell your hard ciders. This element is typically the most notable detail on your label, although you may highlight other aspects of your design. If you don’t have a brand name for your products, you should display the name of the bottler or importer in its place.

Name and address of the bottler (FDA and TTB)

The exact rules for this element differ slightly. Both the FDA and TTB require an address including city and state, but has different rules for the bottler.

FDA – Labels must include the name and address of the premises where the cider was bottled or packed.
TTB – Labels must include the name and address the bottler or importer as listed on the TTB permit. This name must also be preceded by the words “Bottled/Packed by” or “Imported by,” or some qualifying optional statement.

Class, type, or other designation (TTB only)

Any hard cider that is at least 7 percent abv must include a statement of identity. By definition, hard ciders are considered “fruit wine,” but you can simply label your type as “cider” or “hard cider” if your product meets the following criteria.

Produced by the normal alcoholic fermentation of the juice of sound, ripe apples.
Derived wholly (except sugar, water, or added alcohol) from apples.

Net contents (FDA and TTB)

Simply put, hard cider labels must display how much product is in a container. The FDA allows this statement to be listed on any product label. You can also opt to etch or blow the net contents into the container itself.

The TTB is a little more particular about the exact presentation of net contents. As with FDA labeling regulations, net contents can be etched, blown, or displayed on a label. The key difference is that hard ciders of at least 7 percent abv must use the authorized metric standards of fill as listed in the Electronic Code of Federal Regulations (27 CFR 4.72). You also can choose to use any of the following abbreviations:

Milliliters – ml, ML, mL
Liters – L

Alcohol content (FDA and TTB)

The FDA and TTB both require specific statements for total alcohol content and acceptable tolerances. For the FDA, hard cider should state alcohol content as percent by volume and must be within 0.75 percent of what is listed on the label. Meanwhile, the TTB allows for a tolerance of 1.5 percent and mandates that you use one of the following statements to present alcohol content.

Alcohol __% by volume
Alcohol __% to __% by volume (see part 4 for rules)
May use “Alc.” and “Vol.” or “Alc” and “Vol”
May replace “by” with “/”
May NOT use “ABV”

Alcohol content is also one of the elements that follow different type size requirements than the majority of details. The exact rules for type size depend on the size of your container. If the container size is 5 liters or less, you must use a type of 1 millimeter at minimum and 3 millimeters maximum.

Ingredient, nutrition, and allergen listings (FDA)

As an FDA-regulated product, any hard ciders of less than 7 percent abv must include an ingredients list, nutritional facts, and any possible allergens. The FDA’s Food Labeling Guide offers guidelines for the following mandatory elements.

Ingredients – Every ingredient included in your hard cider in descending order of predominance.
Nutritional facts – A detailed breakdown about your hard cider’s nutrient content that follows the formatting requirements (21 CFR 101.9(d)).
Allergens – Call outs if your hard cider includes any of the major food allergens.

Government health warning (FDA and TTB)

As long as your hard cider contains at least 0.5 percent abv, your label must include a warning. This warning is the same for both the FDA and TTB and must read as follows.

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.

This warning can appear on any label as long it remains separate and apart from all other information. The warning should also follow the following type guidelines.

Minimum 3 mm for containers larger than 3 liters (101 fl. oz.)
- No more than 12 characters per inch
Minimum 2 mm for containers larger than 237 ml (8 fl. oz.) to 3 liters (101 fl. oz.)
- No more than 25 characters per inch
Minimum 1 mm for containers of 237 ml (8 fl. oz.) or less
- No more than 40 characters per inch

Specific ingredient declarations (TTB only)

Any wines, hard ciders included, regulated by the TTB must call out certain ingredients if they’re present in the product. As such, you’ll need to disclose that your hard cider contains any or all of the following ingredients if they apply.

FD&C Yellow No. 5
Cochineal extract or carmine
Sulfites (if your cider contains 10 ppm or more sulfur dioxide)

A hard cider bottle with a quality label made with FDA label regulations.

Which Hard Ciders Require a COLA?

The label approval process is another confusing aspect of hard cider label requirements. The FDA does not require pre-approval. Meanwhile, the TTB requires beers, wines, and spirits to apply for and receive a Certificate of Label Approval (COLA) before those products ever hit the market. As such, any hard ciders regulated by the TTB must acquire a COLA before they are packaged and shipped across state lines.

The good news is that it’s fairly simple to apply for a COLA. Breweries can use the COLAs Online Customer Page to register and submit an online application. As long as the TTB finds that you’ve followed all the rules, your label will be good to go.

There is one other alternative to needing a COLA. If you don’t plan to introduce your hard ciders into interstate or foreign commerce, you can apply for a certificate of exemption through TTB Form 5100.31. This exemption will show that your hard cider is exempt from the FAA Act. You will also need to add the following statement to your label.

“For sale in (name of state where bottled) only”

Don’t Let Hard Cider Regulations Detract from Your Products

Let’s face it, TTB and FDA regulations aren’t the most exciting part of your label. The need for key information shouldn’t detract from the appeal of your hard ciders. That’s why Blue Label Packaging Co. works directly with you to print stunning hard cider labels that showcase the quality of your product.

Every label needs to make a great first impression. Our experts work with you to enhance your label design through special materials and eye-catching decorations. We also provide pivotal print protection to prevent premature failure. Contact us today to invest in hard cider labels that help you tell your brand’s story.

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Hard Seltzer Labels: Breaking Down Potential Labeling Regulations

Following alcohol labeling regulations is already a tricky process. It gets even more complicated when you’re unsure which organization oversees the packaging requirements for your product.

Hard seltzers are an increasingly popular beverage for people across North America, but there are some potential problems when it comes to packaging these products. Namely, some hard seltzers fall under different regulatory guidelines than others. Let’s break down exactly why hard seltzers can follow different regulations and what those regulations are.

A collection of cans with hard seltzer labels that follow TTB label requirements.

Does Hard Seltzer Follow TTB or FDA Label Regulations?

The key to identifying which labeling guidelines apply to your hard seltzer depends on how the product is made. While the Alcohol and Tobacco Tax and Trade Bureau (TTB) largely oversees labeling requirements for alcoholic beverages, there are some exceptions that fall within FDA jurisdiction: wines that contain less than seven percent alcohol by volume and beers that aren’t made from malted barley and hops.

What that means for hard seltzer labels is that the base of the beverages will dictate what specific regulations are followed. According to the TTB, hard seltzers made with either malt or sugar bases are considered “beer” products. This means that hard seltzers must follow federal beer laws and should display the following:

The name or trade name of the brewer
The net contents of the bottle
The nature of the product (ex. “beer” or “hard seltzer”)
The place of production
A health warning statement

However, those are not the only labeling requirements for hard seltzers. Malt-based hard seltzers are defined as “malt beverages.” As such, all hard seltzers must follow federal beer rules and additional TTB labeling laws. Meanwhile, sugar-based hard seltzers must instead follow certain FDA labeling rules.

The Differences Between TTB and FDA Regulations for Hard Seltzer Labels

In addition to the federal beer labeling rules, there are other rules that both malt and sugar-based hard seltzers must follow. Both types of hard seltzers must submit a Brewer’s Notice application with the TTB to qualify for production. Furthermore, the TTB must approve the product formula. However, there are some specific TTB and FDA regulations that apply to the different types of hard seltzers.

TTB label requirements for hard seltzers

There are several key elements that the TTB requires for any malt beverage label. Some of these elements are already required by federal beer laws, but the TTB adds on some additional items such as additional rules for class and type designations and disclosures for specific ingredients. The TTB also has specific rules for how each element should be displayed on malt beverage labels. For a detailed breakdown of these requirements, check out our post on TTB label requirements.

Another major difference for malt beverages is the need for a Certificate of Label Approval/Exemption (COLA). The TTB reviews every COLA whether it’s for a new product or if you make changes to your label. Malt-based hard seltzers will need the TTB to approve this COLA before you can sell your products.

FDA label requirements for hard seltzers

Typically, alcohol labels don’t have to disclose ingredients or nutritional information (although it is optional to do so). However, the FDA generally requires food and beverage products to include a nutrition facts panel and ingredients statement on labels. This mandate holds true for alcoholic products that happen to fall under FDA jurisdiction. As such, sugar-based hard seltzers must follow proper nutrition facts panel and ingredients statement protocol as found the FDA’s Food Labeling Guide.

Another big difference between the FDA and TTB is that the FDA doesn’t have a pre-market approval process. While this may sound like a more attractive scenario than submitting a COLA, no pre-approval can open hard seltzer labels up for potential penalties. The FDA will still review and pursue agency action if they discover any labeling issues, so you’ll need to make sure that your packaging is completely compliant before you go to market.

Don’t Skimp on Style for Your Hard Seltzer Labels

Whether your hard seltzers fall under TTB or FDA alcohol regulations, it’s important to make sure your packaging is compliant with existing standards. It’s also critical that your labels do all they can to impress potential customers.

When you need show-stopping hard seltzer labels, Blue Label Packaging can help. Our experts can help you bring your stunning designs to life, find cost-effective solutions that showcase the quality of your products. Contact us today to invest in the perfect labels for your hard seltzers.

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Varietal Wine Labels: How to Follow the TTB’s Rules on Varietal Labeling

From chardonnay to pinot noir, wine types play a significant role in communicating what your bottle has to offer to shoppers, restaurant-goers, and any other form of oenophiles. However, there are some specific rules regarding how you present various varietals on your wine labels.

As with just about everything you need to include on a wine label, the Alcohol and Tobacco Tax and Trade Bureau (TTB) is pretty particular about your varietal presentation. There are three official categories of wine – table wine, dessert wine, and sparkling wine. However, a label may list a specific varietal statement instead as long as you follow a few specific rules.

Meet Minimum Grape Percentage Requirements

If you want to use a specific varietal name, your wine needs to meet some minimum requirements. To start, any wine label with the name of a grape variety must be made from at least 75 percent of the listed type of grape. However, that percentage can change depending on which varietal you use and your region.

In addition to wine type, the TTB also requires that you list an appellation of origin on your label. This appellation is simply a statement of where the dominant grapes used in a wine were grown. This appellation can range from only stating the name of the country to a very specific viticultural area.

As you move into more specific areas, your grape usage requirements can change. For example, certain semi-generic designations like an American marsala may carry additional requirements, such as a certain alcohol range. Each level of geographic detail has its own rules and designations, but that’s a conversation for another blog post. When it comes to varietal rules, the main takeaway is that you use the right percentage of grapes so that the TTB doesn’t turn down your label.

A wine bottle label for Park Farm Winery that lists marechal foch as the varietal of grapes used in the wine.

Use an Approved Varietal

If you’re concerned that the TTB won’t recognize some lesser-known grape varieties, don’t worry. From aglianico to zweigelt, there are more than 300 approved varietal names listed in the Electronic Code of Federal Regulations (e-CFR), all of which are approved for use as a type designation for American wines.

While you may choose to capitalize the names of your varietal or use any hyphens, accents, or any other phonetic marks when printed on your label, the TTB does not require you to do either. As long as you use one of the approved spellings of your grape, or one of the alternative names listed in the e-CFR, you’re all set, regardless of if you opt for a lowercase presentation or choose to remove the umlaut out of grüner veltliner.

If for some reason your preferred varietal is not on the approved list, you’re not completely out of luck. You’ll need to petition the TTB administrator and provide some evidence as to why your grape of choice is deserving of inclusion.

List Breakdowns of Each Varietal if You Use More Than One

There is a way around the 75 percent grape baseline – blends. The TTB allows you to list more than one wine type designation on a label as long as you meet a few different requirements.

First, your wine must be made with all the varieties you list on your label. You can’t include three types that make up 95 percent of your bottle and decide not to include the varietal that makes up the final five percent. Second, you need to include a percentage breakdown of each variety. The TTB gives you a two-percent cushion on accuracy, so you’re fine as long as each type falls within that tolerance.

These rules get a bit trickier with the inclusion of grapes from multiple areas. If your label has multiple counties or states listed as the appellation of origin, you’ll need to include the percentage of each variety by the county or state that variety comes from, which could notably increase the total percentages listed on your bottle.

Two different types of wine listing varietals on their bottle labels.

Follow General Label Guidelines

According to the e-CFR, all wine labels must be “readily legible under ordinary conditions, and all such statement shall be on a contrasting background.” Contrasting backgrounds are simple enough, but what exactly does “readily legible” mean?

Simply put, it means that your type listing, along with other mandatory wine label elements, needs to meet specific TTB rules. The requirements that impact your wine type listings are as follows:

Required text must be at least two millimeters in size for containers of more than 187 milliliters or at least 1 millimeter for containers of less than 187 milliliters
Mandatory information should be in English
Important details should not be obscured by the label itself or any other elements

Of course, these rules don’t mean that you can’t have some fun with how you present your wine type. As long as you meet the guidelines, you can work your varietal’s name into your design to match your style. Compliance doesn’t need to be boring.

Find the Right Packaging Company for Your Wine Labels

When your wine is on the line, it’s important that your labels are more than just fine. Once you have all the mandatory details out of the way, it’s time to find a packaging company that can help you get the most out of your wine labels.

At Blue Label, we have the equipment and expertise necessary to take your labels to the next level. Whether we’re identifying the perfect stock for your wine label or taking advantage of special printing capabilities to amp up your design, we work with you to print the perfect labels for your brand and budget.

Ready to invest in quality labels for your bottles or cans? Contact us today to have us print your next batch of wine labels.

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Pushing the Limit: What Can’t You Do with A Beer Label Design?

Brewers around the world are in a constant battle for people’s attention, whether their products end up on shelves, in coolers, or anywhere else that potential buyers may see their products. In a constant battle for attention, you may want to give your beer labels an extra edge to create a certain brand identity and attract consumers. However, that extra something in your design may be an issue when it comes to label approval.

Whether you’re trying to push some boundaries or simply be clever, your beer label design is ultimately judged by government. The Alcohol and Tobacco Tax and Trade Bureau (TTB) has certain standards for what’s permissible on beer labels. As you may expect, there are a lot of practices that are prohibited for beer label design. The Code of Federal Regulations provides a very long, detailed list, so we’ll try and break down just what may land your design in hot water as succinctly as possible.

What Can’t You Put on a Beer Label?

When you’re trying to push the boundaries with your beer label, it’s important to make sure your design doesn’t conflict with any of the types of statements listed by the TTB. It’s important to note that “statements” applies to more than just text. Anything written, printed, graphic, or portrayed by some other means on a beer label, carton, or case is considered a statement of some sort. As such, any of the following types of statements can lead to the TTB denying your label design.

Untrue or misleading statements

Simply put, the TTB is going to turn you down if they think you’re lying on your label. The TTB considers a statement as untrue if it’s directly false, false by omission, generally ambiguous, or somehow misleading.

For example, a brewery positioning itself to be a microbrewery without meeting the legal definition of one can have its label denied for misleading consumers. Meanwhile, Kona Brewing Company was sued in California for misleading people to think that its beer was brewed in Hawaii. While Kona does use Hawaiian imagery and names, every label clearly states that the beer is not brewed on the island. Because of these statements, the TTB not find the labels misleading (although Kona did eventually agree to a settlement for the lawsuit).

Disparaging statements

While you may want to make a few snide comments about your competitors or some other person or entity, the TTB won’t let you make any statements they determine to be disparaging or hurtful. With that in mind, you may want to rename your batch of “At Least It’s Better Than [Blank] Schwarzbier.”

A Jackie O’s beer label featuring a likeness of a fictional person.

Obscenity or indecency

This section will likely be the biggest hurdle for any brewer trying to test some boundaries. According to the TTB, “any statement, design, device, or representation which is obscene or indecent” is prohibited. However, it’s not always clear what the TTB will consider off limits. This type of ruling is one of the hardest to judge because it depends on what a TTB representative finds obscene or indecent, not you or your customers.

Part of the issue with this type of prohibited statement is that various boards around the country have been inconsistent in past ruling. For example, The Alabama Alcoholic Beverage Control Board banned Founders Brewing Company’s Dirty Bastard Scotch Ale despite having already allowed the sale of Stone Brewing’s Arrogant Bastard Ale (the board eventually reversed its stance on Dirty Bastard after public outcry). As such, rulings on obscenity or indecency are up in the air, so be prepared to change your design or fight against the decision if your label might be construed as offensive in some way.

Improper guarantees or tests

Fortunately, guarantees are easier to identify than obscenity. Any element that provides some form of guarantee – aside from a money-back guarantee – is subject to denial if a TTB official finds that the guarantee may deceive consumers. The TTB will also deny any usage of analyses, standards, or tests that may mislead potential buyers. That means you can’t make a guarantee that your beer will provide short-term happiness, even if you did survey a small test group of patrons.

Names and likenesses

While you may have a great pun based on a celebrity’s names, that play on words can lead to a swift label denial (and potentially a cease and desist letter). The TTB bars the use of any names or likenesses of any prominent living individual or organization, which includes using any simulation or abbreviation to hint at the person or group. This practice is in place to prevent breweries from suggesting that certain people or organizations endorse a product.

For example, Hysteria Brewing Company in Maryland recently ran afoul of this section after using Baltimore Ravens quarterback Lamar Jackson’s likeness on a label after Jackson was named NFL MVP.

However, the TTB does provide some exceptions to this rule. Beer labels may use a person or organization’s name or likeness on a label if:

The individual or organization is engaged in the production of the beer (such as Rogue Ale’s Beard Beer).
A person of a trade or a brand name used the name of any living individual of public prominence, or existing private or public organization, in interest prior to Aug. 29, 1935.

Pretending to be a spirit instead of beer

Depending on your beer, you may want to utilize certain aspects of spirits on your beer label. However, it’s important not to make it seem like your beer is or contains a distilled spirit. Any statement or design element that suggests otherwise can lead to a label denial if the label does not make it clear that the beer is in fact just a beer. For example, a label that truthfully states that the beer was brewed in bourbon barrels is fine, but one that doesn’t contain any references to the product as a beer would is deemed as misleading.

Governmental connections and American insignias

You may want to show off that your beer is proud the be an American, but certain imagery or statements will lead to a quick denial by big brother. These infractions can come in a few forms:

The use of the American flag and any flags, seals, coats of arms, crests, and other insignia associated with the armed forces of the U.S.
The use of the word “bonded” and other variants that may imply governmental supervision over the production of the beer
The simulation or and other design made to resemble stamps for the U.S. or foreign governments

Health-related statements

It may seem funny to make a joke that a beer a day could keep the doctor away, but doing so on a label is a quick way toward having the TTB or some other board turn down your design. Using a health claim on a label is notoriously tricky regardless of product, so it’s best to avoid making any such statements if you’re hoping for label approval, even if that claim is made as a joke.

Shows of strength

Imagine that you brewed a lovely dark beer that clocks in at a relatively hefty ABV. You may want to present to potency of your porter by calling it “strong” on the label. Unfortunately, the TTB isn’t a fan of such language. Any words along the lines of “strong,” “high test,” “high proof,” or other statements that infer alcoholic strength is off limits on beer label unless such language is required by your state’s laws.

Numerals are also a potential pain point. While alcohol by volume statements may use digits, you can’t use numerals elsewhere on your label if it can be considered as a statement of alcoholic content.

A beer label design for Electric Brewing Co. with TTB approval.

What Happens if the TTB Denies Your Beer Label Design?

Let’s pretend that you came up with a great label design and submitted a Certificate of Label Approval (COLA) to the TTB, but the organization rejected your label. Not only is a rejection frustrating, it can also delay your plans since the TTB can take up to 90 days to process a label application. Some reasons for rejection will be easier to fix, such as removing untruthful statements or disallowed imagery. However, more subjective grounds for rejection like what is considered obscene is tricky.

If the TTB denies your application, you’ll either want to modify your design based on the group’s feedback or fight the ruling. One of the most prominent examples of such a fight was when the Michigan Liquor Control Commission found the name and label of Flying Dog Brewery’s Raging Bitch Belgian-Style IPA to be offensive. Flying Dog fought the ruling in various courts until the brewery came out victorious – in 2015 after a six-year battle.

Fortunately for Flying Dog, they had the means and determination to take that fight to court, but you may not want – or be able – to do the same. In that case, it’s better to regroup and think of an alternate solution. For example, Lagunitas Brewing Company made a beer called “The Kronik” that was initially approved in the state of California, but rejected when Lagunitas resubmitted the design in order to sell the beer in multiple states. Fed up with the agency’s inconsistency involving, Lagunitas renamed the beer “Censored” in protest.

Unfortunately, there isn’t always an exact answer as to what will or won’t be approved by the TTB. If you think there may be an issue, it’s always a good practice to hope for the best but prepare for the worst.

My Label Got Approved – What Now?

First off, congratulations! Now that the TTB has signed off on your new label design, it’s time to make sure the finished product does your design justice. At Blue Label, we have the expertise and technology to provide the perfect labels for your beer cans or bottles. We’ll work with you on everything from identifying the right material for your performance needs to providing special printing capabilities that will highlight your design.

Ready to showcase your new beer label design? Contact us today to have us print quality beer labels for your brewery.