27 CFR 5.71 — "Neutral spirits and name of commodity" — sits in Subpart E of TTB's distilled spirits labeling regulations, alongside the better-known mandatory items like brand name and alcohol content. It answers a question consumers cannot answer by taste alone: what was this spirit actually distilled from? Because neutral spirits are, by definition, distilled at or above 95 percent alcohol by volume (190° proof) to near-flavorlessness, the base commodity — grain, cane products, fruit, potatoes, grapes — is invisible in the glass. Section 5.71 makes it visible on the label. Like the rest of Part 5, the section was renumbered in TTB's 2022 recodification (T.D. TTB-176); the equivalent pre-2022 rule lived at old § 5.39, so legacy checklists citing that number are out of date.

The Two Rules Inside § 5.71

The section contains two distinct requirements with different scopes.

Rule 1 — Percentage and commodity for blends (§ 5.71(a)). For distilled spirits manufactured by blending or other processing in which neutral spirits were used, the label must state both the percentage of neutral spirits used and the name of the commodity from which those neutral spirits were distilled. The regulation excludes cordials, liqueurs, flavored neutral spirits (including flavored vodka), and distilled spirits specialty products from this percentage requirement. The statement must appear in substantially one of these forms:

• "____% neutral spirits distilled from ____" (inserting grain, cane products, fruit, or other commodity as appropriate)

• "____% neutral spirits (vodka) distilled from ____"

• "____% grain (cane products) (fruit) neutral spirits"

• "____% grain spirits"

This is the statement you see on blended whisky labels — "60% neutral spirits distilled from grain" — and it works together with the age-and-percentage rules in § 5.74: on a blended whisky under 4 years old, the whisky age-and-percentage statement must appear immediately adjacent to the neutral spirits statement, so the consumer reads the full composition in one place.

Rule 2 — Commodity statement for neutral spirits and continuously distilled gin (§ 5.71(b)). For neutral spirits (which includes vodka, a type within the neutral spirits class under § 5.142) and for gin manufactured by a process of continuous distillation, the label must state the name of the commodity from which the spirits were distilled, in substantially the form: "Distilled from grain" or "Distilled from cane products" (other commodities such as fruit follow the same pattern). No percentage is required here — the product is 100 percent neutral spirits — just the commodity name.

Note the scope carefully on the gin side: § 5.71(b) reaches gin made by continuous distillation (original distillation from a mash with juniper botanicals). Gin made by redistilling or compounding finished neutral spirits is a different production method, and the commodity disclosure obligation attaches through the neutral-spirits pathway rather than paragraph (b)'s gin clause — a distinction worth confirming against your actual production process before finalizing label copy.

Format and Placement

Section 5.71 requires the statement to "appear on a label" — it is not one of the three items that must share the same field of vision under § 5.63 (brand name, class/type designation, alcohol content). In practice, most vodka brands place "Distilled from grain" on the front label near the class designation, but a back-label placement is compliant. The regulatory language "in substantially the following form" gives some flexibility in phrasing, but the safe path is to track the regulation's wording exactly: TTB label specialists reviewing COLA applications compare against the prescribed forms, and creative paraphrases invite correction requests. General advertising must match too — under § 5.233(d), the commodity and percentage statements used in advertisements must be identical to those on the label.

Why It Matters: Grain-to-Glass vs. Sourced GNS

Commodity statements are a quiet battleground in the craft spirits market. A distillery that ferments and distills its own base ("grain-to-glass") and a brand that purchases bulk grain neutral spirits (GNS) from an industrial supplier can both lawfully sell vodka labeled "Distilled from grain" — the statement discloses the commodity, not who distilled it or where. What § 5.71 does force is honesty about the base material: a "potato vodka" positioning collapses if the required statement reads "Distilled from grain," and a brand blending cane-based neutral spirits into a whisky product must say so, with a percentage. Combined with the name-and-address rules in § 5.66 (which govern "distilled by" versus "bottled by" or "produced by" statements), the commodity statement is one of the few label elements that lets a careful reader distinguish authentic production stories from sourced ones. Brands marketing provenance — "estate grown," "farm distilled," single-origin grain — should treat the § 5.71 statement as the anchor their marketing claims must reconcile with, because TTB's prohibited practices rules in Subpart F ban labeling that creates a misleading impression even where each individual statement is technically true.

The Gluten Labeling Adjacency

The commodity statement also intersects with gluten labeling. "Distilled from grain" frequently means wheat, rye, or barley — gluten-containing grains — and shoppers with celiac disease read these statements. Under TTB Ruling 2020-2 (October 2020), TTB permits "gluten-free" claims on spirits distilled from gluten-containing grains, because distillation removes the proteins and protein fragments that constitute gluten, provided good manufacturing practices prevent reintroduction of gluten after distillation (through flavorings, finishing, or cross-contact). This aligned TTB policy with FDA's rule on gluten-free claims for hydrolyzed and distilled foods. The practical result: a wheat-based vodka can simultaneously carry "Distilled from grain" under § 5.71 and "gluten-free" under Ruling 2020-2 — a pairing that looks contradictory to consumers but is fully compliant. Brands should ensure any post-distillation additions preserve the claim, and remember the ruling's different, stricter treatment of fermented (non-distilled) products.

How Truli Helps with Neutral Spirits Commodity Statement Compliance

• Presence checks by product type: Truli's AI agents recognize vodka, continuously distilled gin, and blended spirits from the label and formulation, and flag missing "Distilled from ____" or percentage-of-neutral-spirits statements under § 5.71

• Format verification: Truli compares your statement wording against the prescribed § 5.71(a) and (b) forms, catching paraphrases and missing percentages before they surface as COLA correction requests

• Adjacency validation: For blended whiskies, Truli checks that age-and-percentage statements sit immediately adjacent to the neutral spirits statement as § 5.74 requires

• Claim consistency review: Truli cross-checks commodity statements against marketing claims — potato, cane, or grain positioning, gluten-free claims under TTB Ruling 2020-2, and grain-to-glass provenance stories

Related Regulations

• 27 CFR Part 5 — TTB Distilled Spirits Labeling Requirements — The parent guide to all Part 5 labeling rules

• 27 CFR 5.63 — Mandatory Label Information — The full list of required label statements and placement rules

• 27 CFR 5.74 — Age Statements on Distilled Spirits — The age-and-percentage statements that must sit adjacent to neutral spirits statements on blends

• Distilled Spirits Standards of Identity — Where neutral spirits, vodka, and gin are defined as classes and types

• 27 CFR Part 13 — COLA Label Approval — The approval process where missing commodity statements get caught

Frequently Asked Questions

Does every vodka label need a "Distilled from" statement?
Yes. Vodka is a type within the neutral spirits class, and § 5.71(b) requires neutral spirits labels to state the source commodity — "Distilled from grain," "Distilled from cane products," or the equivalent for another commodity. Flavored vodka is treated differently: it is excluded from the percentage statement in § 5.71(a), and its labeling follows the flavored-spirits rules.

Do liqueurs and canned cocktails made with GNS need a percentage statement?
Generally no. Section 5.71(a) expressly excludes cordials, liqueurs, flavored neutral spirits (including flavored vodka), and distilled spirits specialty products. Many canned cocktails fall into the specialty products category under § 5.156, which takes a statement of composition instead.

Can a wheat-based vodka labeled "Distilled from grain" also claim "gluten-free"?
Yes, under TTB Ruling 2020-2 — distillation removes gluten proteins, so spirits distilled from gluten-containing grains may be labeled "gluten-free" if good manufacturing practices prevent any gluten introduction after distillation. Post-distillation flavorings and finishing agents are the risk to audit.

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