TTB, FLAs and COLAs, oh my! Sit back, relax and get ready for a good time.
The following is a pretty comprehensive list of items needed for a COLA (Certificate/Exemption of Label/Bottle Approval). Some of the basic info is taken from an information sheet given to me by Linda Fox of Compliance Connection in Santa Rosa. So thank you Linda!
The basic mandatory information required on a label includes the Brand name (Capozzi), the class/type, the alcoholic content statement (% Alcohol by volume), the bottler name and address, the contains sulfites declaration (simply “Contains Sulfites”), and the Government Warning statement (”Government Warning: (1) According to the Surgeon General…” etc.). Also, if the net content statement (the volume of wine in the bottle) isn’t blown into the glass itself, the label must also state “750 mL” (for a standard bottle of course) as well.
Interestingly, the vintage date is not mandatory. Considering that consumers seem to particularly confused over what the vintage date actually means, perhaps this isn’t such a bad thing. For the record, the vintage date is the year the grapes were harvested and the wine fermented, not the year the wine was bottled or brought to market. If you do decide to use the vintage date, and most everyone does, other information becomes mandatory, such as appellation of origin (”Russian River Valley”).
If you reference aging on the Front label (which paradoxically can be either on the front or the back of the bottle) you must also list the length of time the wine spent in a fermentation vessel.
You are not required to list the brix at harvest or the residual sugar in the wine unless you use the words “Late Harvest”, “Botrytis” (the fungus responsible for Noble Rot, which makes great dessert wines possible), and “Ice Wine”.
All the above should be at least 2mm tall on the label, except for the alcohol content statement which can be 1mm tall, but can’t be over 3mm tall. Got that? Yeah, me neither.
There are also some prohibited words that absolutely cannot EVER grace the label of a bottle of wine. They include: “Antidote”, “Aperitif” (though you can say that the wine can be used as an aperitif), “Power” or “Powerful” or any other derivative, ditto with “Strong”, “Bold”, “Intense” or “Lively”. These seem to be holdovers from the days of carpet bagging snake-oil salesmen. I would argue that consumers have grown more sophisticated, but then again many don’t know what a vintage date is, so there we are.
Do note the following loophole to the prohibited words: If you deviously slap the word “flavor” after any of the aforementioned words, you’re absolutely fine with Uncle Sam and off the hook.
Finally, there are certain terms that hold no legal meaning that we as producers can take advantage of. One is the term “Old Vine”. Since it has no legal meaning old vine can refer to a 10 year old vine or a 150 year old vine. The test is only that the claim must be true. Let your imagination run wild, basically. However don’t try and use the seemingly generic term “Vintner’s Reserve” on your label; Kendall Jackson has trademarked it.
Well I hope you enjoyed this foray into the exciting world of label regulations. If you’re like me and love absolutely everything having to do with wine, then I’m sure, like me, you found this incredibly dull and tedious. If you are only a casual wine fan and made it this far, I thank you for your support and apologize for your brain having exploded.
