Wine Label FAQs
A Quick Summary of Label Designation Rules:
AVA’s, Varietals, Vineyard Designations and Others
Author: David E. Stoll
March 14, 2005
The following summary lists some of the more commonly encountered label compliance issues under Alcohol and Tobacco Tax and Trade Bureau (TTB) regulations:
A. GEOGRAPHIC AREAS WITH VITICULTURAL SIGNIFICANCE
Section 4.39(i) of TTB’s wine regulations makes it illegal to use a brand name of viticultural significance unless the wine meets the appellation of origin requirements for the named geographical area. A brand name has viticultural significance if it includes the name of a viticultural area. The only exception is for brand names used on existing COLAs prior to July 7, 1986.
1. Appellations of Origin
Definition: An Appellation of Origin is any country, state or county designation used on a wine label.
Rule: A wine must contain at least 75% of grapes from the Appellation of Origin stated on the label.
Example: A wine labeled California must contain at least 75% of grapes from California.
2. American Viticultural Areas (AVAs)
Definition: An AVA is defined as a “delimited grape growing area.” An AVA can be very large, spanning several states, or quite small, such as Anderson Valley, with only 600 acres.
Rule: A wine must contain at least 85% of grapes from the AVA stated on the label (100% if estate designated).
Example: A wine labeled Anderson Valley must contain at least 85% of grapes from the Anderson Valley AVA.
3. Vineyard Designations
Rule: At least 95% of the wine must come from the designated vineyard (100% if estate designated).
B. OTHER BRAND DESIGNATION RULES
1. Vintage Designations
Rule: At least 95% of the wine must come from the vintage designated.
2. Estate Designations
Rule: Wines with “estate bottled” designations must: (a) also designate an appellation of origin or an AVA, and both the vineyards and the winery must be located there; (b) the grapes must come from vineyards owned or controlled by the winery; and (c) the wine must have been produced, from crush to bottle, in a continuous process without leaving the winery’s premises.
For purposes of this section, "controlled by" refers to property on which the bottling winery has the legal right to perform, and does perform, all of the acts common to viticulture under the terms of a lease or similar agreement of at least 3 years duration.
3. Meritage Designations
Rule: According to the Meritage Association’s standards, a wine must meet the following criteria to be labeled Meritage:
Red Wine: A red Meritage must be made from a blend of two or more of the following varietals: Cabernet Sauvignon, Merlot, Cabernet Franc, Malbec, Petit Verdot, St. Macaire, Gros Verdot, or Carmenère. No single variety may make up more than 90 percent of the blend.
White Wine: A white Meritage must be made from a blend of two or more of the following varieties: Sauvignon Blanc, Sémillon, and Sauvignon Vert. No single variety may make up more than 90 percent of the blend.
4. Proprietary Names
Rule: Proprietary names may contain any combination of grapes desired by the winery.
Examples: Opus One, Insignia, Quintessa
5. “Grown, Produced, and Bottled” Designations
Rule: 100% of the grapes must come from vineyards owned or controlled by the producing and bottling winery.
6. “Cellared” or “Prepared”
Rule: The winery must have aged or treated the wine (e.g., racking, filtering, fining, etc.) without changing the wine’s federal “class” or “type”.
7. "Blended”
Rule: The winery must have mixed two or more different wines without changing the wine’s federal “class” or “type”.
C. RULES FOR LESS COMMON GEOGRAPHIC AND OTHER DESIGNATIONS
1. Multiple States Designated on a Label
Rule : Multiple states may be designated on a label if: (a) 100% of the grapes come from the states designated; (b) the percentage of the wine from each state is designated on the label; (c) the wine has been fully produced in one of the names states; and (d) the wine conforms to the laws and regulations concerning composition, manufacture, and designation of wines in all of the designated states.
2. Multiple Counties Designated on a Label
Rule: Multiple counties may be designated on the label if: (a) the counties designated are from the same state; (b) 100% of the grapes come from the counties designated; and (c) the percentage of wine from each county is designated on the label.
3. Multiple AVAs Designated on a Label
Rule: Multiple AVAs may be designated on a label if the wine contains at least 85% of grapes from the area where the AVAs listed overlap.
4. Multiple Varietals Designated on a Label
Rule: Multiple varietals may be designated on a wine label if: (a) 100% of the grapes are of the designated varietals; (b) the % of each varietal is designated on the label.
If you have questions or would like more information on wine label compliance issues, please contact David E. Stoll at 415.954.4964.