On April 27, 2023
Craft Distillers’ Guide to TTB Labeling Requirements
As an alcoholic branding agency, bottle designs thrill us. We live for a good label on a delicious bottle of gin, vodka, whiskey or any fine craft spirit. But before we wrap your products in beautiful branding, we must navigate the rules and regulations of the Alcohol and Tobacco Tax and Trade Bureau (TTB).
If your distillery is working on releasing a new product or redesigning an existing one, it’s important to know your way around the TTB labeling requirements. It starts with certifications and gets even more fun with mandatory information and even type size plays a role.
For anyone ready to take a stab at working through the TTB requirements, we’ve created a brief guide for you here. Let’s get started!
Start at the Beginning: Permits & Registrations
Before even considering products, a distillery must apply for distilled spirits permits. The type of permit needed very much depends on what you plan to do with your business. Any company looking to produce, bottle, process or store spirits will need to register to be a distilled spirits plant (DSP). Luckily, the TTB offers a bit of a walk-through as you get started.
The type of distilled spirits plant registered (whether it’s for beverage, industrial or experimental) entirely depends on the type of spirits operation you’re launching. For instance, if you’re only planning to produce spirits, you’ll only need the beverage registration. However, if the business also bottles and stores spirits, an industrial designation will be needed.
During the permitting process, a distillery needs to create an entity record (for the business) and commodity records for each of the TTB-regulated permits or operations. That means a distillery needs one entity record for the business and a commodity record for its distillery permit. If it chooses to execute other business operations, like brewing.
Aside from permitting through the TTB, all distilleries in the US are required to register with the Food and Drug Administration (FDA) as a food facility.
Next: Producing Spirits
As your distillery begins producing spirits, the TTB requires you to report on production and file Federal Excise Taxes on a predetermined schedule. Distilleries must file these reports on a monthly schedule.
When submitting your operational reports, you’ll need to collect information about the production, processing and/or storage of your products. The type of DSP permit you hold dictates which of those you’ll report on but any distillery distilling, bottling and aging spirits will need to report on all three.
In order to file and pay these monthly taxes, you can use Pay.gov to easily submit the reports and payments. If at any time you make a mistake on your report, resubmit the report as soon as possible through the portal.
Time to Bottle & Label
Long before you get your bottles on a retailer shelf, you need to acquire a Certificate of Label Approval (COLA). By attaining this, you gain the ability to package craft spirits – or import them. However, by receiving that approval, your distillery agrees to follow the labeling rules and regulations that the TTB requires.
Mandatory Distilled Spirits Label Information
The labels created by your distillery should be eye-catching and representative of both your brand and the product. It’s also got to include a really specific list of information. That includes:
- Brand Name: That’s the name of your product – or the name of your distillery in place of a product name.
- Class or Type Designation: What style of spirits you’re packaging based on the definitions from the TTB.
- Alcohol Content: How much alcohol is present in your product based on the alcohol by volume calculation.
- Age Statement: How long the spirit was aged in barrels or elsewhere once it was distilled and before it was bottled.
- Color Ingredient Disclosures: If you’ve used any color additives, the TTB requires that you make that known on your label.
- Commodity Statement: You’ve already identified the class or type designation on the label but you also need to create a statement about the percentage of neutral spirits in the product as well as the commodity (primary distillate) used to create the product.
- Health Warning Statement: That standard government warning from the surgeon general needs to be included.
- Name and Address: Your distillery should be credited for the creation of this product and the location of that creation needs to be disclosed as well.
- Net Contents: How much product is in the bottle? It should be expressed in liters and milliliters.
- Country of Origin: Tell your customers where this product originates from.
Guidance on Other Optional Label Information
- Distinctive or Fanciful Name: When more than a brand name is needed to describe your product, this is what you add to your label. Some specialty spirits require this.
- Alcohol Content: Yes, you’ve already got the alcohol by volume on there but you also have the option of dropping in degrees of proof.
- Dietary Information: Some distillers may want to a Gluten Content Statement, Major Food Allergen Labeling or statements related to nutrients. That’s entirely up to you but we recommend submitting this if it aligns with your distillery’s goals.
- Production Claims: If you’d like to share organic claims or other production claims on your label, you have the option to do so.
- For any other personalization, the TTB offers a good deal of guidance.
Whatever you choose to put on your label, it needs to match up with exactly what you’ve submitted for your COLA application.
It can be an intimidating process. And on top of it all, you need to develop a label that will sell your products. If you need a hand wading through all of these rules, regulations and laws, work with an alcohol branding agency like High-Proof Creative. We have the liquor packaging design experience you need. Set up a consultation and we’ll walk you through all of it.