Distilled spirits labeling is governed by 27 CFR Part 5, reorganized top to bottom by TTB in 2022 — old section numbers like 5.36 and 5.40 no longer exist, and a few substantive rules changed with them. Add the Government Warning in 27 CFR Part 16 and you have the federal rulebook for every spirits label. Here is what must appear, where it must appear, and the identity rules underneath.

The mandatory statements — and the field-of-vision rule

27 CFR 5.63 splits mandatory information into two placement tiers. Three items must appear together within the same field of vision — meaning a single side of the container, defined for cylindrical bottles as 40 percent of the circumference, viewable without turning the bottle. The rest can go anywhere on the container.

The field-of-vision rule is a 2022 liberalization — the old regime forced brand name and class onto the front "brand label" — but it still catches designs that scatter ABV to a back panel.

Class and type — the standards of identity

Every spirit must be designated by the class or type it actually meets under the standards of identity in 27 CFR 5.141 through 5.156. These are recipe-level legal definitions, and the whisky table in 27 CFR 5.143 is the most litigated square inch of them.

Bourbon must be made in the United States from a fermented mash of at least 51 percent corn, distilled at no more than 160° proof, entered into the barrel at no more than 125° proof, and stored in charred new oak containers. There is no minimum aging time for plain "bourbon" — but adding "straight" requires at least 2 years in those containers, and any straight whisky aged under 4 years must carry an age statement. Whisky must be bottled at not less than 80° proof. The newest entry: American single malt whisky, added to 5.143 by a 2024 final rule — 100 percent malted barley, distilled at one US distillery.

Designation errors are a leading COLA rejection cause, especially for RTDs and flavored products whose designation must match an approved formula. Our COLA walkthrough covers that sequencing.

Alcohol content and proof

Under 27 CFR 5.65, alcohol content must be stated as a percentage of alcohol by volume — "Alcohol __% by volume" or an approved variant. A proof statement is optional, permitted in addition to (never instead of) the ABV statement. The tolerance is plus or minus 0.3 percentage points (27 CFR 5.65(c)) — a 2022 change that loosened the old 0.15-point rule, though products with spirits-absorbing solids like fruit must instead state alcohol content "at time of bottling."

Net contents and standards of fill

Spirits cannot be sold in any bottle size you like. Containers must match an authorized standard of fill in 27 CFR 5.203 — a list TTB has expanded significantly since 2020 to include sizes like 700 mL, 720 mL, 900 mL, and can-friendly volumes like 355 mL and 250 mL, alongside the classics (50 mL, 375 mL, 750 mL, 1 L, 1.75 L). The net contents statement itself must be in metric, and it may be blown, embossed, or molded into the glass.

Age statements — optional until they're mandatory

27 CFR 5.74(b) makes age statements mandatory for any whisky aged less than 4 years, including blends containing any component under 4 years (bottled-in-bond products excepted). Above 4 years, age statements are optional — but once used, the format is prescribed: "__ years old," stating the age of the youngest whisky in the bottle. Blends containing neutral spirits trigger combined age-and-percentage statements with their own required wording, and US whisky aged in reused barrels (outside corn and single malt types) must say "stored __ years in reused cooperage" instead of claiming age at all.

State of distillation and commodity statements

Two disclosure rules unique to spirits round out the mandatory set:

• State of distillation — under 27 CFR 5.66(f), US-distilled whiskies of most types in 5.143 must disclose the state where original distillation occurred: via a "distilled by" address, a "bottled by" address in the distilling state, the state name next to the designation ("Kentucky bourbon whisky" — only if distilled and aged there), or a plain "Distilled in [State]" line. This is the rule behind sourced-whiskey controversies: an Indiana-distilled bourbon cannot dress itself in another state.

• Neutral spirits commodity statements — under 27 CFR 5.71, blended products made with neutral spirits must state the percentage and source ("__% neutral spirits distilled from grain"), and gin or neutral spirits made by continuous distillation must state the base commodity ("Distilled from grain").

The Government Warning — and what's coming

Every spirits container needs the health warning of 27 CFR 16.21: exact wording, "GOVERNMENT WARNING" in bold capitals with nothing else bolded, separate and apart from other text, minimum type sizes by container volume. It remains the top typography failure in COLA review — details in our rejections post. Looking ahead, TTB's pending Alcohol Facts rulemaking would add a per-serving alcohol and nutrition panel to every spirits label; our Alcohol Facts breakdown covers the proposal and how to prepare.

Put your spirits label through TTB's rulebook first

Truli's AI agents check spirits labels against the current text of 27 CFR parts 5 and 16 — designations against standards of identity, age statement logic, ABV format and tolerance, standards of fill, state of distillation, and the Government Warning — citing the exact rule behind every finding, then scan your packaging, website, and social content the same way. Book a demo to see your label the way a TTB reviewer will.

A note from Truli: Truli is not a law firm, and this article does not constitute or contain legal advice or create an attorney-client relationship. When determining your obligations and compliance with respect to relevant laws and regulations, you should consult a licensed attorney.