Making Wine for Commercial Sale from a Kit? You Might Need Formula Approval and a Statement of Composition
Recently, TTB has seen more applications for formula and label approval from producers using winemaking kits. Winemaking kits for wine that require formula approval typically contain concentrate, yeast, juice from multiple fruits and/or agricultural products, flavor packets, artificial sweeteners, acids, sulfites and wood chips. These kits provide sufficient materials to produce several bottles of wine.
As a reminder, TTB does not generally regulate the production, sale, or use of winemaking kits. However, TTB does regulate the commercial production of wine (i.e., wine that is produced for sale or production in excess of the personal or family use limitations in 27 CFR 24.75), which can include the production of wine from kits. TTB’s IRC and FAA Act authority requiring formula and label approval apply. See TTB FAQ W14b.
Producers using winemaking kits for commercial production are fully responsible for obtaining formula approval, when required, and obtaining the necessary information about the content of the kits to support any statements made on the label. See TTB FAQ W14a.
Formulas: You can use TTB’s wine formula tool to determine if your wine requires formula approval. When making wine from a kit for commercial sale, keep in mind that you will need formula approval if, among other things:
- The kit contains both fruit and authorized agricultural products (for example, strawberry and honey);
- The wine produced from the kit is mixed with juice or wine produced from a different type of fruit or authorized agricultural product (for example, the kit produces apple wine that is mixed with rhubarb juice or wine after the apples were fermented);
- Any of the following are added, either as part of the kit or separately:
- Flavors
- Artificial sweeteners
- Colors
Labels: You must obtain a Certificate of Label Approval (COLA) for wine 7 % alc./vol. and above that is bottled for sale in interstate commerce and will be required to provide enough information on the label to adequately inform the consumer about the identity and quality of the product in accordance with TTB regulations. See TTB FAQ W14b.
Note: Winemakers must maintain complete records so that any information (whether mandatory or optional) that is stated on the formula application or on the label may be verified by a TTB audit (see TTB FAQ W14c).
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