TTB and the contortions of going through Label Approvals

by Jana Harvey on March 11, 2009

For the last week I’ve been working on getting label approvals from the TTB (Tax & Trade Bureau).  All wine labels have to be inspected and approved by the federal government.  As with most federal bureaus these days they are extremely over worked. I have had labels they have previously approved, only to be rejected this time.  It seems a lot is left to interpretation by the individual inspector.  I have also had rejected labels, where I waited a month sending them in again, getting them back with the TTB stamp of approval.  You learn not to argue with them.  Just do what they ask and be very polite.

 

A good example is our fortified wine we call Forté.  It is a fortified wine made just like you would make Port in

Portugal

from all Portuguese varieties.  Forte 05P_B Being a European trained wine maker I will not use European place names on our wines.  So we call the wine “Forté” rather than Port.  In 2004 when I first obtained label approval for this wine the back label said “A California Port Style Wine.”  This time the term “A California Port Style Wine” was rejected.  They said I had to use “Red Table Wine”.  I said, “It is not red table wine, it is a fortified wine”.  They said I could not use the word fortified on a wine label so therefore had to use “Red Table Wine”   I pointed out to them that that would be lying to the consumer.  They didn’t seem to care, stating that was the regulation.

 

Knowing that using “Red Table Wine” on this wine would be a marketing nightmare, I politely ask what other alternatives there were.  TTB said I could list the varieties and their percentages.  So I re-submitted the label with the percentages and the varieties.  It was again rejected.  I again politely called them and asked them why.  They said one of the varieties “Sousao” did not exist in their list of accepted wine varieties.   I’m thinking that’s odd, it is a fairly common variety in

Portugal

.  I thinking, it has to exist and kept questioning the inspector for a good 20 minutes, before I finally asked if he had a variety on the list spelled some what like Sousao.  He looked at the list and said there is one spelled Souzao.  I go great, I’ll re-submit with Souzao and it was finally approved.

 

Another example of the label coming before different inspectors with them telling me I had to do contradicting things is with our Napa Valley Old Vine Riesling.  I moved the production of this wine to one of Cosentino’s Winerys in Lockeford which is near

Lodi

.  I wanted the produced and bottled by statement on the back of the bottle to reflect that we are a Napa Valley Company.  Rather than just saying “Produced and Bottled by

Jana

Winery, Lockeford, CA”  I had the statement read “Produced and bottled by

Jana

Winery, Lockeford, CA for

Jana

Winery, Napa Valley, CA.”  On the first bottling this statement was accepted.  The next year when I sent it in the new inspector rejected it.  Again, after a 20 minute polite phone call I finally got it out of the inspector why he was rejecting it.  He decided that the place had to be a city not a place, so

Napa

Valley

was unacceptable since it carries no postal address.  Luckily, there is a town in

Napa

Valley

by the name of

Napa

.  So I asked him if I dropped the Valley off of it to read “ Produced and bottled by

Jana

Winery,

Lockeford

,

CA

for

Jana

Winery Napa, Ca” if that was okay.  I sent it in again hoping he would get the application and not the first inspector that approved the previous one.  He got it and it was approved.

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