Having trouble viewing this email? View it as a Web page.

File Disaster Claims – Disaster Relief

March 7, 2025

What Appellation of Origin Can Be Used on Wine from Grapes or Juice Purchased from Another State?

[Photo credit: Google, Gemini 2.0, https://gemini.google.com]

We are often asked: What appellation can I use on wines produced from grapes or juice from a different state?  The answer really depends on the particular circumstances, including whether the states are adjacent.

How to get it right?

Review TTB regulations and guidance. Start by checking Federal requirements at 27 CFR 4.25(b). We also offer additional information and scenarios to illustrate different circumstances at FAQ A25. For example:

Scenario 1: The wine is produced in State A with grapes grown in an American Viticultural Area (AVA) fully contained in adjacent State B.

• The most specific appellation of origin eligible for use is the name of the adjacent state (here, State B). An AVA may NOT be used as the appellation of origin because the wine was not fully finished within that state—i.e., it was finished in State A and not State B, in which the AVA is located.

Scenario 2: The wine is produced in State A with grapes grown in State C, which is not adjacent to State A.

• The most specific appellation of origin eligible for use is a country appellation, such as "American." A wine may only be labeled with a state appellation if it has been fully finished (except for cellar treatment pursuant to 27 CFR 4.22(c), and blending which does not result in an alteration of class or type under 27 CFR 4.22(b)) within the labeled state or an adjacent state. Note that when a country is used as an appellation of origin a vintage date is NOT permissible for the wine.

Check with state and local authorities. Note that state or local laws and regulations may be more restrictive than Federal laws and regulations in some instances, and, to use an appellation, the wine must conform to the laws and regulations of the named appellation area. We advise that you confer with state and local authorities regarding their requirements before finalizing your COLA submission.

Keep your records. Remember that your wine, and the records that you keep, must adequately support any claims that are made on your label.

For more information on appellations and AVAs, watch our new video: TTB Boot Camp for Wineries: Beyond the Basics - AVAs!

Does Your Alcohol Beverage Product Contain a Compounded Flavor?

[Photo credit: Google, Gemini 2.0, https://gemini.google.com]

When you apply for formula approval of an alcohol beverage, you are required to provide information about the ingredients used in the production of the alcohol beverage. Missing required information can delay your product approval – and a common mistake is failing to provide necessary information when you use compounded flavors.

How to avoid delays:

If you're using a compounded flavor that was purchased from a flavor manufacturer, you should submit a Flavor Ingredient Data sheet (FID sheet) with your alcohol beverage formula. A compounded flavor includes any flavor, cloudifier, or blender that consists of multiple ingredients that are combined to produce a particular taste characteristic.

Flavor manufacturers do not typically provide detailed information about the composition of their flavors to alcohol beverage manufacturers, but you need to know what TTB and Food and Drug Administration (FDA) limited ingredients are present in the flavors to ensure your beverages do not exceed allowable limits. The FID sheet is a way for the flavor manufacturer to provide the necessary information about limited ingredients.

TTB Accepts Offers in Compromise

We have accepted offers in compromise from Hard Truth Distilling Company LLC for failing to timely file and pay federal excise tax and from SDS Imports LLC for improperly claiming operating expenses as eligible adjustments to taxable sales, improperly excluding and deducting ineligible expenses from federal excise tax, failing to maintain supporting documentation sufficient to justify the exclusion of nontaxable articles from taxable sales, failing to timely file and pay excise tax, and failing to report all taxable sales.

You may view all TTB administrative actions on TTB.gov.

What's Trending on TTB.gov: Top Business Central Pages

• Alcohol Beverage Authorities in United States, Canada, and Puerto Rico
• Preparing Tax Returns and Reports: Helpful Hints and Tips
• Responsibilities for Approved Industry Members
• Alcohol Beverage Advertising
• TTB Learning Center: Get Training

For More TTB News

TTB.gov Home

Newsletters Archive

Contact TTB