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highwood28

Spirits Case Labels

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Working with graphics guys on printed cases and doing some research. I can’t seem to find TTB requirements on case labels. I have seen to following on cases in stores and am looking for guidance on the requirements for these

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Well, you give a lot of examples, but try this for the definitive answer 🙂:

Sec. 19.483  Specifications for marks.

 

    (a) Basic requirements. A proprietor must place the marks prescribed by this subpart on cases, encased containers, and packages of spirits and denatured spirits so that they are:

    (1) Of adequate size to be easily read;

    (2) Of a color in distinct contrast to the color of the background;

    (3) Legible; and

    (4) Durably affixed.

    (b) Use of labels. A proprietor may use labels as the means for applying prescribed marks if the labels meet the requirements of paragraph (a) of this section.

    (c) Location. A proprietor must place the prescribed marks on one side of the case or encased container, or on the head of the package.

 

Sec. 19.489  Marks on cases filled in processing.

 

    (a) Mandatory marks. Except for cases marked in accordance with Sec. 19.496, a proprietor must mark in accordance with Sec. 19.483 the following information on each case of spirits filled in processing (you bottle in processing and must put the bottles into cases:

    (1) Serial number in accordance with Sec. 19.490 (every case must be serially numbered, but I thnk many small bottlers miss this requirement);

    (2) Kind of spirits in accordance with the classes and types of spirits set forth in part 5 of this chapter (see 5.35 and 5.22);

    (3) The distilled spirits plant number where bottled;

    (4) Date filled;

    (5) Proof; and

    (6) Liters or proof gallons.

    (b) Export marks. In addition to the marks referred to in paragraph (a) of this section, the proprietor must include the marks required by part 28 of this chapter on cases removed for export, for transfer to any customs bonded warehouses, for transfer to foreign trade zones, or for use as supplies on certain vessels and aircraft.

    (c) Other marks. A proprietor may include other marks on cases filled in processing in addition to the marks prescribed under this section. Any additional marks must not interfere with, or detract from, the marks prescribed in this section. The proprietor may include other marks such as:

    (1) The name or trade name, and the location if desired, of the bottler, displayed with the word ``Bottler'';

    (2) For products distilled or processed by the proprietor, the proprietor's name or trade name, and the location of the distilled spirits plant, if desired, displayed with the words ``Distiller'' or ``Processor'', as applicable;

    (3) For products imported and bottled by the proprietor, the words ``Imported and Bottled By'', followed by the proprietor's name or tradename and location of the distilled spirits plant if desired;

    (4) For products bottled for a dealer, the words ``Bottled For'', followed by the name of that dealer;

    (5) Any material required by Federal or State law and regulations; and

    (6) Labels or data describing the contents for commercial identification or accounting purposes or indicating payment of State or local taxes.

 

That should do it.  

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We use Hoochware and it prints our labels for us, which include the information you wrote about, @dhdunbar. I like to stick with what the rules say we need to include, but I've always been curious about how the cases from the large manufacturers never seem to have all of the information required by the CFRs. Could they possibly be packaging in larger bulk and the label they place on that larger unit somehow be missing from the smaller cases? 

 

For instance, I all the examples the OP offered, I see only deep Eddy included the Liters explicitly (most included some variation of 6x750ml). We include proof gallons on ours and I'm surprised that's not what is included on more cases. I also noticed most examples did not include a date filled like we do on ours. Any guesses?

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Multiple choice:

  • (a) Very few people get audited.  :-). 
  • (b) What an auditor looks at depends on the scope of the audit, which might not include looking at the case labeling :-).
  • (c) The auditor may not care about case markings and uses independent judgement :-). 
  • (d) TTB has so many problems that it doesn't want to have to deal with minutia :-).  
  • (e) All of the above.

Important - TTB gets to pick what it looks at when it visits.  It gets to say what is important and what is not.  For example, however obvious it may be, you do not get to decide if paying taxes is more important than putting a serial number on a gauge record.  TTB can look at whatever it wants.  It can cite "picky" violations.  You just don't know what it will do.  If you do your best to comply, TTB will see that.  Trying matters to them.

 

 

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