Contains Sulfites Labeling for a Rum

[joefreas]

Hi,

I am working through my first COLA submission and I am a bit confused on the disclosure section of the label. Do I need to put "contains sulfites" on the label. We are not importing and havent been required to do lab analysis. I don't see it on any of the rum labels so I was wondering if it was a requirement?

Thanks,

Joe-

[fldme]

Why would you need to do that? Are you adding sulfites? Rum does not need sulfites.

[joefreas]

Thank you for your reply. I was a little confused by the wording in the Beverage Alcohol Manual. I have since got it cleared up. Here is an excerpt from the BAM on p.11.

11. SULFITE DECLARATION

REQUIRED

“CONTAINS SULFITES” or “CONTAINS (A) SULFITING AGENT(S)” or

identification of the specific sulfiting agent(s) is required on distilled spirits

containing 10 or more parts per million (ppm) sulfur dioxide

TYPE SIZE

Minimum 2 mm for containers larger than 200 ml

Minimum 1 mm for containers of 200 ml or less

LEGIBILITY

Must generally appear parallel to the base of the container

Must be readily legible

Must appear on a contrasting background

Must appear separate and apart or substantially more conspicuous than any

other descriptive or explanatory information

PLACEMENT

May appear on the FRONT, BACK or SIDE

of the container

It is funny how complicated these things seem until you get through a few.