27 CFR 5.66 governs the name and address statement for domestically bottled distilled spirits wholly made in the United States under the post-2022 recodification of Part 5 (spirits with imported content follow § 5.67 or § 5.68 instead). The statement may appear anywhere on the container under § 5.63(b), but its content is tightly scripted: who gets named, what function phrase precedes the name, what the address must contain, and — for most American whiskies — where the spirit was actually distilled. TTB amended the section as recently as December 2024 (T.D. TTB-199), so older summaries may miss the current whisky-type scope.

Who Must Be Named and How (§ 5.66(a)–(b))

The label must identify the bottler, distiller, or processor by a phrase describing the function that person actually performed, followed by their name and address. For purposes of the section, a processor who solely bottles the spirits is considered the bottler. The prescribed phrases:

• Bottler: "bottled by," "canned by," "packed by," or "filled by"

• Processor: "blended by," "made by," "prepared by," "produced by," or "manufactured by," as appropriate — and note that for distilled spirits, "produced by" indicates a processing (formerly rectification) operation that changes the class or type through added flavors or other processing, not distillation

• Distiller: "distilled by" — and if the spirits were bottled for the distiller, "distilled by and bottled for" or "bottled for"

The function phrases carry real information. "Distilled by" is a claim that the named company ran the still; "produced by" is, counterintuitively, a processing claim. If a person performs multiple functions the label may say so, but under § 5.66(c), when different functions are performed by more than one person, the label may not create the misleading impression that they were performed by the same person — the paragraph that makes a craft brand's label read differently when someone else did the distilling.

Address Rules and Contract Bottling (§ 5.66(d))

The address is the city and State where the operation occurred (or of the principal place of business), and it must be consistent with the basic permit. Street addresses, zip codes, and websites are optional extras. Key flexibilities, each with a catch:

• Multiple plants: an operator of several distilled spirits plants may list the other plant addresses, but the place where the operation actually occurred must be indicated on the label or container by printing or coding

• Principal place of business: may substitute for the operational address, again only if the actual location is indicated by printing, coding, or other markings

• Bottled for another person: if spirits are bottled for someone other than the actual distiller, the label may add — but never substitute — that person's name and address preceded by "bottled for" or similar, and the statement must clearly indicate the relationship between the two persons (for example, contract bottling)

• Additional addresses for the same person are allowed only where a bona fide alcohol beverage business actually operates there, with descriptive material stating the function performed at that place

Section 5.66(e) adds a special rule for combined straight whiskies of the same type from different distillers in the same State: the label may replace the bottler statement with "distilled by" followed by each distiller's name (or trade name) and address and the percentage each distilled, within a tolerance of plus or minus 2 percent.

State of Distillation for Whisky (§ 5.66(f))

For whisky distilled in the United States of any type defined in § 5.143(c)(2) through (7), (15), and (16) — the enumerated whisky types including bourbon, rye, wheat, malt, and rye malt whisky and their counterparts, a scope TTB extended in the December 2024 amendment — the State of original distillation must appear on the label. It may appear on any label, in at least one of four ways:

1. A "distilled by" statement (or any phrase including the word "distilled") in the name-and-address statement, followed by a single location

2. A "bottled by" statement whose address includes the State where distillation occurred

3. The State name immediately adjacent to the class/type designation — "Kentucky bourbon whisky" — permitted only if the whisky was both distilled and aged in that State per § 5.143(b)

4. A separate statement such as "Distilled in [name of State]"

Two enforcement hooks follow. Under § 5.66(f)(2), TTB may require the state of distillation or other information to appear (and may prescribe its placement) whenever necessary to negate a misleading impression about the actual State of distillation — even if the State technically appears somewhere in the address. And under § 5.66(f)(3), for "light whisky" the State names "Kentucky" and "Tennessee" may not appear on the label at all except within a permitted name-and-address statement.

The Sourced Whiskey Transparency Problem

Section 5.66 is the regulatory front line of the sourced-whiskey debate. A large share of American whiskey brands buy distillate from large contract distillers — most famously MGP in Lawrenceburg, Indiana — then age, blend, bottle, and market it under a craft brand story. The rules above make bare-minimum honesty mandatory: the bottler statement must name who actually bottled, the state of distillation must surface for the covered whisky types, and the label cannot imply one company did work another performed.

The gap between minimum compliance and marketing narrative is where litigation lives. Templeton Rye is the canonical example: the Iowa-marketed brand was sued in class actions because its rye — promoted with "small batch" and Iowa Prohibition-era heritage claims — was distilled at MGP in Indiana. Templeton settled in 2015 for $2.5 million, adding "distilled in Indiana" to its label and dropping "Prohibition Era Recipe" and "small batch" (The Spirits Business, Top Class Actions). Tito's Handmade Vodka faced parallel "handmade" class actions (largely defeated, and involving a vodka — outside § 5.66(f)'s whisky scope). The lesson: a COLA-approved label is not a safe harbor against state consumer-protection claims when the brand story outruns the name-and-address facts.

Imports and Trade Names

Section 5.66 covers only spirits wholly made in the United States. Imported bottled spirits carry an importer statement under § 5.67; spirits bottled domestically after import follow § 5.68 — while the § 5.66(f) state-of-distillation rule applies by its terms to covered whisky types distilled in the United States. Names in the statement must be consistent with the basic permit, and § 5.66(e) expressly contemplates operating under trade names — but a trade name cannot be deployed to blur who performed which function, which would run into § 5.66(c).

How Truli Helps with Name, Address, and Origin Compliance

• Function-phrase validation: Truli's AI label scans check that "bottled by," "distilled by," and "produced by" statements match the functions actually performed and flag statements that imply a single actor performed split functions, per § 5.66(b)–(c)

• State-of-distillation checks: Truli verifies that covered whisky types under § 5.66(f) disclose the State of original distillation in one of the four permitted forms, and flags adjacent-to-designation State names that require in-State distilling and aging

• Origin-story screening: Truli's marketing scans compare label and campaign claims ("handmade," heritage, place-based stories) against the name-and-address facts — the gap that drove the Templeton Rye litigation

• COLA-readiness review: Truli's alcohol vertical checks the full name-and-address statement against basic-permit consistency and contract-bottling disclosure rules before submission

Related Regulations

• 27 CFR Part 5 — TTB Distilled Spirits Labeling Requirements — The parent guide to the full distilled spirits labeling framework

• 27 CFR 5.63 — Mandatory Spirits Label Information — Where the name-and-address statement fits in the placement scheme

• 27 CFR 5.143 — Whisky and Bourbon Labeling — The whisky types that trigger the state-of-distillation rule

• 27 CFR 5.74 — Spirits Age Statements — The other disclosure sourced whiskey brands must manage

• 27 CFR Part 13 — COLA Label Approval — The review process that checks name-and-address statements

Frequently Asked Questions

I buy whiskey from MGP and bottle it under my brand — what must my label say?
At minimum, a truthful bottler statement ("bottled by [you], [city], [state]") and, for covered whisky types under § 5.66(f), the State of original distillation — for MGP distillate, Indiana — shown in one of the four permitted ways, such as "Distilled in Indiana." Your label also may not imply you distilled it, and your marketing story can create liability under state consumer-protection law even if the label passes TTB review.

Can I use my company headquarters as the label address?
Yes — § 5.66(d)(3) allows the principal place of business in lieu of where the operation occurred, but only if the actual place of the operation is indicated on the label or container by printing, coding, or other markings, and the statement stays consistent with your basic permit.

When can a label say "Kentucky bourbon whisky"?
Only when the whisky was both distilled and aged in Kentucky, per § 5.66(f)(1)(iii) and § 5.143(b). Placing a State name immediately adjacent to the class/type designation is the strictest of the four state-of-distillation options — bourbon distilled in Kentucky but aged elsewhere must disclose Kentucky another way, without the adjacent placement.

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 5.66 as of August 2026, including the December 2024 amendment (T.D. TTB-199). Truli monitors TTB rulemaking and enforcement. Book a demo to see how.