27 CFR 4.38, titled "General requirements," collects the formatting rules that apply across all the mandatory statements of Part 4 — brand name, class and type designation, alcohol content, net contents, name and address, and the sulfite declaration. Where §§ 4.32 through 4.37 say what must appear, § 4.38 says how: minimum type sizes keyed to container size, legibility and contrast standards, the English language requirement, and physical rules about how labels attach to the container. TTB applies these requirements during COLA review, so a formatting miss surfaces as a label rejection before the wine ever ships.

Legibility and Contrast (§ 4.38(a))

All labels must be designed so that every statement required by §§ 4.30 through 4.39 is readily legible under ordinary conditions, and all such statements must appear on a contrasting background. This is a functional standard rather than a numeric one: low-contrast foil stamping, tone-on-tone printing, and script faces that sacrifice readability can all draw a rejection even when the type technically meets the millimeter minimums. The safest design practice is to isolate mandatory statements from decorative treatments entirely.

Minimum Type Sizes (§ 4.38(b))

The type size floor for mandatory information depends on container size, with a single breakpoint at 187 milliliters:

Both tiers carry the same conspicuousness rule: if mandatory information appears among other descriptive or explanatory information, it must be in script, type, or printing substantially more conspicuous than that surrounding text. Burying the sulfite declaration inside a back label paragraph of tasting notes at the same size violates § 4.38(b) even if the type measures 2 mm.

The measurements refer to the actual printed height of the script, type, or printing — as a rule of thumb, 2 mm corresponds to roughly 8-point type and 1 mm to roughly 4-point, but point sizes vary by typeface, so compliant labels are verified by measuring the printed characters, not the font setting.

Two practical notes for pre-press. First, measure on a printed proof at final scale: artwork approved on screen routinely drops below the minimums when the die line is reduced for a small-format bottle. Second, the breakpoint follows the container, not the label — a back label shared between a 750 mL bottle and a 187 mL split must satisfy 2 mm on the former even though 1 mm would suffice on the latter.

The Alcohol Content Band: 1 mm to 3 mm (§ 4.38(b)(3))

The alcohol content statement is the one mandatory item with both a floor and a ceiling. On containers of 5 liters or less, it may not appear in script, type, or printing larger or more conspicuous than 3 millimeters nor smaller than 1 millimeter, and it may not be set off with a border or otherwise accentuated. Note the asymmetry with the general rule: on a 750 mL bottle, ordinary mandatory text must be at least 2 mm, but the alcohol statement may go as small as 1 mm — and no larger than 3 mm. The ceiling exists so that alcohol strength is disclosed without being marketed; a label that showcases "15.2%" in display type is exactly what the provision prohibits.

English Language Requirement (§ 4.38(c))

All mandatory label information must be stated in the English language, with a narrow exception: the brand name, place of production, and the name of the manufacturer, producer, blender, bottler, packer, or shipper need not be in English if the words "product of" immediately precede the country of origin stated per customs requirements. That is how a French label may carry "Mis en bouteille au château" alongside an English mandatory set. Additional statements in foreign languages are permitted so long as they do not conflict with or contradict any requirement of §§ 4.30 through 4.39 — a full foreign-language back label is fine, but it cannot replace the English mandatory statements or qualify them into ambiguity.

Firmly Affixed Labels and Placement (§ 4.38(d), (e))

Two physical rules round out the presentation requirements. Labels must not obscure Government stamps, nor be obscured by them (§ 4.38(d)). And all labels must be affixed so that they cannot be removed without thorough application of water or other solvents (§ 4.38(e)) — the "firmly affixed" rule. Hang tags, sleeves, and removable stickers therefore cannot carry mandatory information; anything that satisfies §§ 4.32 through 4.37 must be on a label that is permanently part of the container. This matters for can sleeves and shrink wraps too: the mandatory set has to live on material that meets the firmly-affixed standard.

Additional Labels and Additional Information (§ 4.38(f))

Wine labels may carry information beyond the mandatory set — back labels, neck labels, and strip labels are all permitted — provided the additional material complies with §§ 4.30 through 4.39 and does not conflict with or in any manner qualify the required statements. Beyond that, added content must be truthful, accurate, and specific, and neither disparaging nor misleading. Section 4.38(f) is the hook TTB uses against creative copy that undermines a mandatory statement, and it works in tandem with the prohibited practices in § 4.39. Note that certain mandatory items carry their own placement flexibility: the sulfite declaration, for example, may appear on a front, back, strip, or neck label under § 4.32(e).

Ingredient Representations and Records (§ 4.38(g), (h))

If a label makes any representation about the presence, excellence, or other characteristic of an ingredient in the wine or used in its production — beyond required statements and permitted percentage statements — the label must state, substantially as conspicuously as the representation itself, the name and amount in percent by volume of each such ingredient (§ 4.38(g)). Touting "finished with French oak brandy" triggers a quantified disclosure. Finally, § 4.38(h) authorizes TTB to demand a full and accurate statement of the contents of any container to which labels are to be, or have been, affixed — the records hook behind the formatting rules.

How Truli Helps with Label Format Compliance

• Type size screening: Truli measures mandatory statements on label artwork against the 2 mm and 1 mm floors for the container size, and checks the alcohol statement against the 1–3 mm band and no-accentuation rule

• Contrast and legibility flags: Truli identifies low-contrast mandatory text and mandatory statements buried inside descriptive copy without the required conspicuousness

• Language checks: Truli verifies that every mandatory statement appears in English and that foreign-language content does not contradict or qualify the required set

• Full-label review: Truli evaluates back, neck, and strip label content under § 4.38(f) alongside the § 4.39 prohibited practices before COLA submission

Related Regulations

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

• 27 CFR 4.32 — Mandatory Wine Label Information — The statements these formatting rules apply to

• 27 CFR 4.36 — Wine Alcohol Content Statements — The statement subject to the 1–3 mm band

• 27 CFR 4.37 — Wine Net Contents and Standards of Fill — The companion mandatory statement and container rules

• 27 CFR 4.39 — Prohibited Practices on Wine Labels — The content prohibitions that work alongside § 4.38(f)

Frequently Asked Questions

What is the minimum type size on a standard 750 mL wine bottle?
2 mm for all mandatory information, because 750 mL is more than the 187 mL breakpoint — except the alcohol content statement, which may be as small as 1 mm but no larger or more conspicuous than 3 mm on containers of 5 liters or less.

Can I put the mandatory statements on a hang tag or removable sticker?
No. Under § 4.38(e), labels must be affixed so they cannot be removed without thorough application of water or other solvents. Mandatory information must appear on firmly affixed labels; tags, sleeves that slip off, and peelable stickers do not qualify.

My label is entirely in French. Is that allowed?
Not for the mandatory statements. All mandatory information must be in English under § 4.38(c); the exception covers only the brand name, place of production, and producer or bottler name when "product of" precedes the country of origin. Foreign-language text may appear in addition to, never instead of, the English mandatory set.

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 4.38 as of August 2026. Truli monitors TTB rulemaking and enforcement. Book a demo to see how.