Understanding Labeling Requirements for Your Beverage Alcohol Product
Accurate beverage alcohol labeling is more than a box checking exercise — it’s essential to avoid costly delays, refused shipments, or legal penalties.
Say your winery has a fantastic new Cabernet Sauvignon nearly ready for shipment. You’re proud of the blend, your bottles look beautiful, your marketing team nailed promo, and you're eager to start selling. But discovering a mandatory detail on your label is missing or incorrect can quickly derail your success.
At BBG, our team has decades of experience navigating the labyrinthine regulatory framework for producing and selling alcohol. Learn the ins and outs of beverage alcohol labeling requirements below.
Mandatory Information for Beverage Alcohol Labels
Before submitting any label for approval, make sure it includes all mandatory information. TTB regulations and state guidelines clearly outline which details must appear on your alcohol labels, and missing even one critical alcohol beverage labeling detail can be costly.
Here's a checklist of the TTB label requirements for alcohol to keep you compliant and TTB audit-ready:
Brand name: Your brand name should clearly and truthfully represent your product to consumers. Choose a name that won’t confuse, mislead, or infringe on existing trademarks, and always verify it matches precisely with your COLA submission — I've witnessed labels rejected simply due to small discrepancies here.
Class or type designation: Class type would be Cabernet Sauvignon, Single Malt Scotch, IPA, or Sparkling Rosé. Misclassification, even by accident, delays approvals and can lead to fines or recalls down the road.
Alcohol content by volume (ABV): Clearly state the percentage of alcohol by volume. This isn't a place for estimates; your ABV statement must match precisely with laboratory testing results. Inaccurate ABV statements trigger swift regulatory actions, including product recalls, consumer complaints, or legal challenges.
Net contents: State how much beverage is in your container using approved measurements (milliliters for wine and spirits, fluid ounces or pints for beer). An incorrect, inconsistent, or improperly converted net content statement — such as labeling a 750 ml bottle as 700 ml — can immediately halt distribution.
Producer or importer identification: Clearly indicate who bottled, produced, or imported the beverage, including name and full address. I've seen labels rejected because this information was outdated or didn't match TTB records precisely.
Mandatory government health warning: Include the exact government health warning as specified by the TTB. Formatting mistakes, incorrect punctuation, inconsistent placement, or deviations in wording are major red flags.
Sulfite declaration for wines: All wines containing 10 parts per million or more of sulfur dioxide must carry the sulfite declaration. Forgetting this one line has led many producers into expensive reprints, compliance violations, and distribution delays.
Country of origin for imports: If you're importing beverages, your labels must clearly state the country of origin. Missing, vague, or incorrect country-of-origin declarations are among the top reasons import labels are denied approval.
Allergen statements: Declare common allergens clearly, such as wheat in beer or sulfites in wine. Overlooking allergen disclosures is a critical mistake that can risk consumer health and trigger recalls.
Additional disclosures when necessary: Ingredients such as FD&C dyes, carmine coloring, or artificial flavoring agents must be explicitly stated. I've advised clients through tricky situations where undeclared additives caused serious alcohol product labeling compliance issues.
The TTB Label Approval Process: Obtaining a COLA
Once your label includes all required details, the next critical step is securing TTB’s Certificate of Label Approval or COLA. A COLA is essential for legally selling beverage alcohol products interstate, as it formally indicates your label complies fully with federal regulations.
Begin by finalizing your label design with all mandatory information clearly displayed. If your product includes unusual ingredients, ensure any required TTB formula approvals are obtained before submitting your COLA. Log into the TTB’s COLAs Online system and carefully fill out form 5100.31, entering your brand name, type of alcohol, exact alcohol content, and net contents precisely as shown on your label image. Upload your label in a clear, high-resolution format to ensure readability.
Once submitted, your application enters TTB’s queue, and review times typically range from a few days to several weeks, depending on current workload. Delays are often caused by simple yet avoidable issues like mismatched label and application details, prohibited language, unclear label images, lack of necessary formula approval, or incomplete applications.
To minimize such setbacks, double-check every detail on your submission against your actual label before submitting. At BBG, we rigorously cross-check all label applications against your final label for quick approval and avoid unnecessary delays.
Navigating State-Specific Beverage Alcohol Labeling Requirements
Federal compliance through TTB approval is critical, but in my years helping wineries and producers navigate compliance at BBG, Rodney Strong, and Dickenson Peatman & Fogarty, I've found that state-level regulations can introduce complexities that federal guidelines simply don’t cover.
Even if you've received your COLA, overlooking state-specific variations can lead directly to fines and penalties — and believe me, that’s a headache no producer wants during a critical launch period.
To give you a clearer idea of what to expect, let’s look at some state-specific alcohol label regulations where beverage alcohol labeling requirements differ:
California requires Proposition 65 warnings, which go far beyond federal health warnings. You’ll need clear statements on your label about potential exposure to alcohol-related health risks and specific chemicals linked to cancer or reproductive harm. Many producers entering California underestimate the detail needed here, resulting in costly relabeling and delays.
Illinois recently enacted strict labeling regulations for alcohol-infused products, such as hard kombucha or alcoholic seltzers. These products must have clear labels in retail settings to prevent confusion with non-alcoholic beverages, which goes beyond federal mandates.
Staying updated across multiple states is a lot of work, but it doesn't have to be a time suck. At BBG, we help clients keep detailed compliance calendars, subscribe to state regulatory alerts, and regularly verify details directly through state agencies.
Common Labeling Mistakes and How to Avoid Them
Let's look at common mistakes that hinder beverage alcohol label approval and how to avoid them:
One of the most common mistakes I see producers make is mislabeling the alcohol content by volume (ABV). Your ABV statement must match your final laboratory results exactly. Even small discrepancies between your label and lab report can lead to rejections or costly legal complications.
I've seen labels rejected simply because the government health warning wasn't formatted correctly — it really isn't something you can modify or stylize to fit your brand. The TTB requires specific wording, capitalization, punctuation, and bold text.
Many wineries overlook the required sulfite declaration, particularly if they’re new to compliance. If your wine contains 10 ppm or more of sulfur dioxide, you must clearly state this on your labels.
Another frequent error involves inaccurate net contents statements. Pay careful attention to unit conversions, especially when switching between fluid ounces and milliliters.
Not addressing state-specific requirements is another major oversight. I always recommend verifying state regulations directly, because assuming federal approval means state compliance is one of the easiest and most costly mistakes to make.
Labeling a bourbon merely as "whiskey" or incorrectly classifying your red blend can result in delays or fines. I've seen products held up for weeks because producers didn’t carefully select the exact class or type designation recognized by the TTB.
Leveraging Expert Guidance to Streamline Label Compliance
Partnering with compliance experts like Balanced Business Group significantly simplifies this complex process. Our dedicated compliance specialists meticulously review labels, guide you through the COLA submission process, and handle the intricacies of state-level label compliance.
BBG’s involvement has helped wineries and beverage producers achieve faster approvals, drastically reduce compliance risks, streamline multi-state market expansions, and minimize costly mistakes. Our proactive approach also enables producers to confidently focus their resources on crafting quality products, managing marketing strategies, and strengthening distributor relationships.
Ensure Compliance and Market Success with Accurate Labeling
Accurate and compliant labeling is foundational to successfully launching your beverage alcohol products.
If you’re unsure whether your beverage alcohol labels meet compliance standards or simply need peace of mind, contact Balanced Business Group. Our compliance experts will help with beverage alcohol labeling requirements to make sure your products are compliant and ready for market. Get in touch today to learn more.
Cheers to your compliant, successful beverage alcohol launch!
Author: Nicole Elizabeth
Nicole Elizabeth is a seasoned expert in Alcoholic Beverage Compliance with over a decade of experience in the wine industry. As the Compliance Team Lead at BBG, she advises wineries on navigating complex regulatory landscapes. Nicole’s previous roles as an Alcohol Beverage Paralegal at Dickenson Peatman & Fogarty and Compliance Specialist at Rodney Strong Vineyards have given her deep expertise in licensing, reporting, and compliance issues. With a background in Wine Studies and Marketing from Sonoma State University, Nicole brings a comprehensive understanding of both the regulatory and business aspects of the wine industry.
