27 CFR Part 4 contains the Alcohol and Tobacco Tax and Trade Bureau's (TTB) labeling and advertising regulations for wine, issued under the Federal Alcohol Administration (FAA) Act. The part defines which wines TTB regulates, what information must appear on the label, how that information must be presented, what statements are prohibited, and when a certificate of label approval (COLA) is required before bottling or importation.

Who Must Comply

Under 27 CFR 4.6, Part 4 applies to wine containing not less than 7 percent and not more than 24 percent alcohol by volume. This tracks the FAA Act's definition of wine.

Products that would otherwise meet the definition of wine but contain less than 7 percent alcohol by volume — many wine coolers, low-alcohol wine products, and some ciders — are outside Part 4 entirely. Under 27 CFR 4.7, bottlers and importers of those products should refer to FDA's food labeling regulations at 21 CFR Part 101 instead. In practice this means a 6.5% ABV wine product needs an ingredient list and Nutrition Facts-style compliance under FDA rules, while an 8% ABV wine needs a TTB-compliant label and a COLA.

Note that the federal health warning statement under 27 CFR Part 16 applies to all alcoholic beverages containing 0.5 percent or more alcohol by volume — including sub-7% wine products that are otherwise FDA-labeled.

Mandatory Label Information (§ 4.32)

27 CFR 4.32 lists the mandatory label information and splits it between the brand label (the principal display label) and any label on the container:

Brand name (§ 4.33). Every wine must bear a brand name. If the wine is not sold under a brand name, the name of the bottler or packer on the brand label is treated as the brand name. Brand names may not mislead as to the age, origin, identity, or other characteristics of the wine.

Class and type designation (§ 4.34). The class of the wine must be stated in conformity with the standards of identity in Subpart C of Part 4. For still grape wine, a varietal designation, semi-generic geographic type designation, or geographic distinctive designation may appear in lieu of the class designation. If the wine's class is not defined in Subpart C, the label must instead carry a truthful and adequate statement of composition. All parts of the designation must appear in direct conjunction, in lettering substantially of the same size and kind.

Name and address (§ 4.35). American wine must state "bottled by" or "packed by" followed by the bottler's or packer's name and address. Optional supplemental terms are strictly defined: "Produced" or "Made" requires that the named winery fermented not less than 75 percent of the wine at the stated address (or changed its class or type, or produced sparkling wine by secondary fermentation there); "Blended," "Cellared," "Vinted," and "Prepared" each carry their own definitions.

Net contents (§ 4.37). Net contents must be stated in metric measure — in liters (to the nearest hundredth) above one liter, and in milliliters below one liter — consistent with the authorized standards of fill in § 4.72.

Alcohol Content and Tolerances (§ 4.36)

Under 27 CFR 4.36, alcohol content must be stated for wines containing more than 14 percent alcohol by volume. For wines at 14 percent or less, the statement is optional if the type designation "table" wine or "light" wine appears on the brand label.

When stated, alcohol content must be expressed as a percentage of alcohol by volume ("Alcohol __% by volume" or a similar phrase). TTB permits a labeling tolerance between the stated and actual alcohol content:

The tolerance cannot be used to cross a tax class or class/type boundary (see § 4.36(c)). A wine labeled 13.9% ABV that actually measures 14.5% has a problem regardless of the 1.5-point tolerance, because the stated and actual contents fall in different categories.

Sulfite Declaration (§ 4.32(e))

If sulfur dioxide or a sulfiting agent is detected at a level of 10 or more parts per million, measured as total sulfur dioxide, the label must state "Contains sulfites", "Contains (a) sulfiting agent(s)", or a statement identifying the specific sulfiting agent. The declaration may appear on a front, back, strip, or neck label. Because most wines exceed 10 ppm total SO2 through normal winemaking, the sulfite declaration is effectively universal on commercial wine labels.

Appellation, Varietal, and Vintage Claims

Part 4 also governs the optional-but-regulated origin and composition claims that drive wine marketing. In overview:

• Varietal labeling (§ 4.23) — a grape variety name generally requires that at least 75 percent of the wine derive from that variety and that an appellation of origin appear

• Appellations of origin (§ 4.25) — country, state, county, and American Viticultural Area (AVA) appellations each carry minimum-content and other eligibility rules

• Vintage wine (§ 4.27) — a vintage date requires an appellation and a minimum percentage of the wine from the labeled year

Each of these carries detailed percentage thresholds and conditions that go beyond this overview — see the companion guide on wine appellations, varietals, and vintage dates for the full requirements.

Type Size and Legibility (§ 4.38)

27 CFR 4.38 sets general presentation requirements: mandatory information must be legible, on a contrasting background, and in minimum type sizes:

The alcohol content statement has its own rule: on containers of 5 liters or less it may be no larger or more conspicuous than 3 mm and no smaller than 1 mm, and may not be set off with a border or otherwise accentuated. Mandatory information appearing among other descriptive text must be substantially more conspicuous than that text.

Prohibited Practices (§ 4.39)

27 CFR 4.39 prohibits, among other things:

• False or misleading statements — including statements that mislead by ambiguity, omission, inference, or the addition of irrelevant scientific or technical matter

• Disparagement of a competitor's products, and obscene or indecent material

• Statements about analyses, standards, tests, or guarantees likely to mislead the consumer

• Names of living persons of public prominence or existing organizations used in a way that falsely implies endorsement

• Any representation that the wine contains distilled spirits, is comparable to a distilled spirit, or has intoxicating qualities

• Simulated designations — coined words or names that imitate a class, type, or permitted designation the wine is not entitled to bear, and distilled-spirits cocktail names such as "Manhattan" or "Martini" in a wine's brand name or designation

Section 4.39 also restricts health-related statements on wine labels, paralleling the rules for distilled spirits and malt beverages.

Certificate of Label Approval (§ 4.50)

Under 27 CFR 4.50, no person may bottle or pack wine, or remove it from the bottling plant, without an approved certificate of label approval (COLA) on TTB Form 5100.31 — unless the bottler holds a certificate of exemption for wine that will not enter interstate commerce. Imported wine likewise requires a COLA before release from customs custody. TTB reviews the label against Part 4 during COLA processing, so most of the requirements above are enforced at the point of label approval, before the wine ever reaches the market.

TTB has also proposed an Alcohol Facts rule (Notice No. 237, January 2025, with an extended comment period) that would add mandatory per-serving alcohol, calorie, and nutrient disclosures to wine labels, together with a companion major-allergen labeling proposal. Both remain proposed rules — not final requirements — as of August 2026, but wineries should anticipate label revisions if they are finalized.

How Truli Helps with Wine Label Compliance

• Full-label scanning against Part 4: Truli's AI agents check wine labels for every mandatory statement — brand name, class/type designation, alcohol content, net contents, name and address, and the sulfite declaration — citing the specific section for each finding

• Tolerance and type-size checks: Truli flags alcohol content statements outside the § 4.36 tolerance format and mandatory text that appears to fall below § 4.38 minimum type sizes

• Prohibited practice detection: Truli screens label and marketing copy for § 4.39 issues, including misleading statements, implied endorsements, and distilled-spirits comparisons

• COLA-readiness review: Truli runs a pre-submission check so labels arrive at TTB's COLA queue without the common rejection triggers

Related Regulations

• 27 CFR Part 5 — Distilled Spirits Labeling — TTB's parallel labeling rules for distilled spirits

• 27 CFR Part 7 — Malt Beverage Labeling — TTB's parallel labeling rules for beer and other malt beverages

• 27 CFR Part 16 — Health Warning Statement — The GOVERNMENT WARNING required on all alcoholic beverages at 0.5% ABV or more

• 27 CFR Part 13 — COLA Label Approval — How TTB issues, revokes, and appeals certificates of label approval

• Wine Appellations, Varietals, and Vintage Dates — The detailed origin and composition rules deferred from this overview

Frequently Asked Questions

Does my wine label need to state alcohol content?
Only if the wine contains more than 14 percent alcohol by volume. At 14 percent or less, § 4.36 makes the statement optional provided the designation "table" wine or "light" wine appears on the brand label. In practice, nearly all producers state alcohol content anyway, and it must then follow the required format and tolerances.

My wine is 6.5% ABV. Do I follow TTB or FDA labeling rules?
FDA. Under § 4.7, wine-type products under 7 percent alcohol by volume are outside Part 4 and are labeled under FDA's food regulations at 21 CFR Part 101 — including an ingredient list. The Part 16 health warning statement still applies because the product exceeds 0.5 percent ABV.

Is the "Contains sulfites" statement always required?
It is required whenever total sulfur dioxide is detected at 10 ppm or more, per § 4.32(e). Wines below that threshold, verified by analysis, may omit it — and only wines verified below 10 ppm can support "no sulfites added" style claims. Most conventionally made wines exceed 10 ppm.

Can I sell wine without a COLA if it never leaves my state?
Wine sold purely intrastate may qualify for a certificate of exemption from label approval rather than a COLA, but the bottler must apply for and receive the exemption, and state label rules still apply. Any wine shipped in interstate commerce requires an approved COLA under § 4.50 before bottling or removal.

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 Part 4 as of August 2026. Truli monitors TTB rulemaking and enforcement, including the pending Alcohol Facts proposal. Book a demo to see how.