Wednesday, November 10, 2010

TTB Label Terms

The TTB recently invited comments by publishing in the Federa Register proposed changes to the definition of certain words on wine labels. As someone that is often asked if certain terms are allowed on a bottle, this rule may actually affect a much larger number of wineries than people would assume or that may be aware of these rules. Mostly, this is because many people in the industry are not aware of the ramifications of placing the word Estate on their label or that by defining words, the TTB could have a direct affect on the value of their vineyards.

First, the TTB is proposing to codify the position that Estate Grown may only be used on wine that meets the requirements of Estate Bottled under 27 CFR 4.26. Essentially, the wine must be grown on vineyards controlled by the winery, crushed, fermented and bottled by the winery and within the AVA on the label. If you have presently use Estate Grown on your labels without complying with this requirement, your label approvals could be revoked and would not be exempt from this ruling.

Second, the TTB is looking at defining what a vineyard, farm or ranch is with regard to vineyard designation or claims of single vineyard on the label. For owners of these properties who value the ability to designate wines, it would seem that this could be a very important issue. A definition could limit a vineyad name to a certain AVA or area, such that vineyards which cross these lines would have to maintain two names. A vineyards could be defined as a contiguous parcel, such that Vineyards that are not entirely connected would have to have seperate names. This might dramatically affect the value of grapes from these seperated portions of your property.

Finally, the TTB is proposing to define a number of terms that are often added to a wineries description of the wine. These terms are such as: Proprietor Grown, Vintner Grown, Proprietors Blend, Old Vine, Barrel Fermented, Old Clone, Reserve, Select Harvested, Bottle Aged, and Barrel Select. If your winery uses any of these terms in its programs, you will want to be sure that what ever the basis is for your claim to these terms is incorporated into the rules. Otherwise, you label approvals could be revoked and you could find yourself in violation of TTB rules for continuing your past practices.

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