27 CFR 4.35 governs the name and address statement — the mandatory line identifying who bottled, packed, or imported the wine and where. It is deceptively technical: beyond the baseline "bottled by" requirement, the section converts everyday winemaking words into defined terms. "Produced by" is not marketing copy; it is a certification that the named winery fermented at least 75 percent of the wine at the stated address. Because retailers, sommeliers, and critics have learned to decode these terms, the name and address statement doubles as the label's provenance disclosure — and misusing a defined term is both a COLA rejection and a credibility problem.

The Mandatory Statement for American Wine (§ 4.35(a)(1))

A label on each container of American wine must state either "bottled by" or "packed by", followed by the name of the bottler or packer and the address of the place where the wine was bottled or packed. That is the floor: every American wine label carries at least this statement, on any label on the container per § 4.32(b). Other words may be added only in accordance with the optional-statement rules below.

The label may also name any other person for whom the wine was bottled or packed, immediately preceded by "bottled for", "packed for", or "distributed by" — the standard formulation for private-label and négociant-style arrangements where the brand owner is not the bottler.

The Defined Production Terms (§ 4.35(a)(2))

Section 4.35(a)(2) defines the optional terms that may be conjoined with the mandatory statement. Each certifies a specific operation performed by the named winery at the stated address:

• "Produced" or "Made" — the named winery (A) fermented not less than 75 percent of the wine at the stated address, or (B) changed the class or type of the wine by addition of alcohol, brandy, flavors, colors, or artificial carbonation there, or (C) produced sparkling wine by secondary fermentation there. Note that "Made" carries the identical definition — it is not a softer synonym

• "Blended" — the named winery mixed the wine with other wines of the same class and type at the stated address

• "Cellared", "Vinted", or "Prepared" — the named winery subjected the wine to cellar treatment in accordance with § 4.22(c) at the stated address

The conjunction rules matter: these words may be joined with "bottled by"/"packed by" using "and" (as in "Produced and bottled by") only if the same person performed the defined operation at the same address. If a different person performed the operation, more than one name is required; if it happened at a different address, more than one address is required. "Produced and bottled by XYZ Winery, Napa, CA" therefore asserts that XYZ both fermented 75 percent or more of the wine and bottled it at that Napa address.

Why the Trade Reads These Terms as Provenance Signals

Because the definitions are enforced at label approval, the industry treats the § 4.35 line as a truthful sorting mechanism. "Produced and bottled by" signals estate-style control: the named winery actually fermented the great majority of the wine. "Cellared and bottled by" or "Vinted and bottled by" signals the opposite — the named winery may have purchased finished bulk wine and performed only cellar treatment (filtering, aging, finishing) before bottling. Retail buyers, critics, and informed consumers routinely use this distinction to separate genuine producers from brands built on the bulk market, particularly in oversupplied vintages when négociant labels proliferate. Nothing about "Cellared by" is non-compliant — but a winery that fermented its own wine and settles for "Cellared by" is leaving a legally certified provenance claim on the table, and a brand using "Produced by" without the fermentation records to prove 75 percent is exposed at audit.

Imported Wine: "Imported by" and Its Variants (§ 4.35(b))

A label on each container of imported wine must state "imported by" or a similar appropriate phrase, followed immediately by the name of the importer, agent, sole distributor, or other person responsible for the importation, and the address of their principal place of business in the United States.

If the wine was bottled or packed in the United States, an additional statement is required — one of:

• "Bottled by"/"packed by" with the U.S. bottler's or packer's name and address; or

• "Imported by and bottled (packed) in the United States for" (or similar) where the wine was bottled for the importer, with the importer's name and U.S. address; or

• "Imported and bottled (packed) by" where the importer itself bottled the wine, with its name and U.S. address

Wine blended, bottled, or packed in a third country (not the country of origin) must disclose that operation — "blended by", "bottled by", or similar — with the name and place, where the label identifies the country of origin. Optionally, the label may state the foreign producer's name and principal place of business, and may use foreign winemaking terms (or English equivalents) as permitted by the country of origin for domestic sales there.

Address Form and Trade Names (§ 4.35(c)-(d))

The "place" stated must be the post office address shown on the basic permit or other qualifying document for the premises where the operation took place, with an address shown for each operation designated on the label — for example, "Produced at Gilroy, California, and bottled at San Mateo, California, by XYZ Winery" (the street address may be omitted). Additional places or addresses for the same person may not be listed unless that person actively conducts a bona fide alcohol beverage business there and the label describes the function occurring at that additional address. This blocks the borrowed-prestige move of listing a Napa office address on wine bottled elsewhere.

Under § 4.35(d), any trade or operating name on the label must be identical to a name appearing on the basic permit or other qualifying document. A doing-business-as brand identity that has not been added to the TTB permit cannot appear in the name and address statement.

Common Findings in Practice

The recurring § 4.35 problems are: "Produced by" without 75 percent fermentation at the stated address (or records to prove it); conjoined statements ("Produced and bottled by") where the operations happened at different addresses or by different entities; trade names that do not match the basic permit; missing U.S. bottling statements on imports bottled domestically; and vanity addresses without a disclosed function. Each is checkable before submission from the winery's own permit and production records.

How Truli Helps with Name and Address Compliance

• Defined-term verification: Truli's AI label scans parse the name and address statement and flag defined terms — Produced, Made, Blended, Cellared, Vinted, Prepared — that the product's stated production history cannot support, citing § 4.35(a)(2) per finding

• Import statement checks: Truli verifies "Imported by" formulations and the additional U.S. bottling statements required when imported wine is bottled or packed domestically

• Permit consistency: Truli flags trade names and addresses that appear inconsistent with the operating names and premises disclosed elsewhere in your product records

• COLA-readiness review: Truli tests the full name and address block against TTB's most common corrections before the label reaches the COLA queue

Related Regulations

• 27 CFR Part 4 — TTB Wine Labeling Requirements — The full Part 4 overview this section belongs to

• 27 CFR 4.32 — Mandatory Wine Label Information — Where the name and address requirement sits in the mandatory checklist

• 27 CFR 4.33 — Wine Brand Name Rules — When the bottler's name doubles as the brand name

• 27 CFR 4.38 — Wine Label Format and Type Size — Legibility and type-size rules the statement must meet

• 27 CFR Part 13 — COLA Label Approval — How name and address findings surface in label approval

Frequently Asked Questions

What is the legal difference between "Produced by" and "Cellared by"?
"Produced by" (and "Made by") certifies that the named winery fermented at least 75 percent of the wine at the stated address, changed its class or type there, or produced sparkling wine by secondary fermentation there. "Cellared by" (and "Vinted by"/"Prepared by") certifies only that the winery gave the wine cellar treatment under § 4.22(c) at the stated address — it says nothing about who fermented it, which is why the trade reads it as a bulk-wine signal.

Can I write "Produced and bottled by" if we fermented at one facility and bottled at another?
Only with both addresses shown. The terms may be conjoined with "and" only when the same person performed both operations at the same address; different addresses require a statement for each, such as "Produced at [address one] and bottled at [address two] by XYZ Winery."

What must an imported wine's label say if it is bottled in the U.S.?
Two things: the "Imported by" statement with the responsible party's name and principal U.S. business address, plus a U.S. bottling statement — "bottled by" with the domestic bottler's name and address, "imported by and bottled in the United States for" the importer, or "imported and bottled by" the importer if it bottled the wine itself.

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.

Last updated: August 2026. Reflects 27 CFR 4.35 as of August 2026. Truli monitors TTB rulemaking and enforcement. Book a demo to see how.