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Label Compliance Guide for Alcoholic Beverages in the US – Part 3

October 24, 2018

A quick recap: Part 1 of this series introduced the readers to the regulations that govern labeling requirements for Wine, Distilled Spirits and Malt Beverages in the United States. Part 2 explained provisions under Labeling Proceedings as well as Labeling and Advertising of Wine.

This post will look at the labeling requirements for distilled spirits as stipulated under 27 CFR Part 5. While this part applies to “the several states of the US, the District of Columbia and the Commonwealth of Puerto Rico”, it does not apply to “distilled spirits for export.”

According to Part 5, Distilled Spirits include: Ethyl Alcohol, Hydrated Oxide of Ethyl, Spirits of Wine, Whisky, Rum, Brandy, Gin and other Distilled Spirits, including all dilutions and mixtures thereof, for nonindustrial use. However, it does not include: mixtures containing wine, bottled at 48 degrees of proof or less, if the mixture contains more than 50 percent wine on a proof gallon basis.

The standards for identity in section 5.22 of the part, defines the classes and types of distilled spirits as follows:

  • Class 1 – Neutral Spirits or Alcohol, Vodka, Grain Spirits
  • Class 2 – Whisky:
    • Bourbon, Rye, Wheat, Malt, Rye Malt
    • Corn
    • Whisky distilled from bourbon mash
    • Light
    • Blended
    • A Blend of Straight
    • Spirit
    • Scotch
    • Irish
    • Canadian
  • Class 3 – Gin:
    • Dry – London Dry
    • Geneva – Hollands
    • Old Tom – Tom
  • Class 4 – Brandy
    • Fruit
    • Cognac
    • Dried Fruit
    • Lees
    • Pomace or Marc
    • Residue
    • Neutral
    • Substandard
    • Pisco
      • Pisco Peru
      • Chilean Pisco
    • Class 5 – Blended Applejack
    • Class 6 – Rum
      • Cachaca
    • Class 7 – Tequila
    • Class 8 – Cordials and Liqueurs
      • Sloe gin
      • Rye, bourbon cordial
      • Rock and rye, rock and bourbon, rock and brandy, rock and rum
      • Rum liqueur, gin liqueur, brandy liqueur
    • Class 9 – flavored brandy, flavored gin, flavored rum, flavored vodka, and flavored whisky
    • Class 10 – Imitations
    • Class 11 – Geographical Designations
    • Class 12 – Products without geographical designations but distinctive of a particular place

It is prohibited to sell bottles of distilled spirits that are unmarked, not branded and not labeled.

The following information is mandatory to be present on the Principal Display Panel on the front of the container: Type size: Minimum 2 mm on containers larger than 200 ml and minimum 1 mm on containers of 200 ml or less.

A. Brand Namename under which the distilled spirit is marketed. There are no type size specifications. However, the name cannot describe the age, origin, identity or other characteristics of the distilled spirits unless the name accurately describes the distilled spirits and conveys no erroneous information or is qualified with the word “BRAND”

B. Class and Type Designation

C. Alcoholic Content% alcohol by volume. Additionally, it can be expressed in degree proof set off by parenthesis, brackets, dots or otherwise distinguished from (but not more prominent than) alcohol by volume statement

D. Net Contentsfor spirits packaged in containers for which no standard of fill is prescribed in this part.

On the brand label/PDP or the back label, the following information should be given:

E. Name and Addressbottler or packer or filler and/or distiller, blender, maker, preparer, manufacturer or producer. Must appear on label preceded by appropriate explanatory phrase such as “BOTTLED BY” or “DISTILLED BY”. For imported spirits

  1. For spirits bottled, packed or filled prior to importation – name and address of importer preceded by “IMPORTED BY,” “SOLE AGENT” or “SOLE U. S. AGENT”
  2. For spirits bottled, packed or filled after importation – name and address of the importer and/or bottler, packer or filler preceded by “BOTTLED BY,” “IMPORTED AND BOTTLED BY,” “IMPORTED BY AND BOTTLED FOR” or “IMPORTED BY ___________ AND BOTTLED BY ___________”

F. Country of Origin in case of imported spirits

G. Net Contentsfor spirits packaged in containers for which standard of fill is prescribed in this part.

H. Coloring or flavoring

I. A statement that the product contains FD&C Yellow No. 5

J. A statement that the product contains the color additive – ex: “Contains Cochineal Extract” or “Contains Carmine” or, if applicable, “Contains Cochineal Extract and Carmine”)

K. Declaration of sulfites

L. Percentage of neutral spirits and name of commodity from which distilled

M. A statement of age or age and percentage

N. State of distillation of domestic types of whisky and straight whisky, except light whisky and blends

Health Warning Statement:

GOVERNMENT WARNING: (1) According to the Surgeon General, women should not drink alcoholic beverages during pregnancy because of the risk of birth defects. (2) Consumption of alcoholic beverages impairs your ability to drive a car or operate machinery, and may cause health problems.

Type Size: minimum 3 mm for containers larger than 3 liters (101 fl. oz.), minimum 2 mm for containers larger than 237 ml (8 fl. oz.) to 3 liters (101 fl. oz.) and minimum 1 mm for containers of 237 ml or less. The characters per inch requirements are as follows:

  • 1 mm – max 40 characters per inch
  • 2 mm – max 25 characters per inch
  • 3 mm – max 12 characters per inch


  • Treatment with wood if applicable “COLORED AND FLAVORED WITH WOOD _________” (insert chips, slabs, extracts, etc., as appropriate)

Commodity Statements are statements disclosing the percentage of neutral spirits and the commodity from which the neutral spirits were distilled. State of distillation applicable only to whisky produced in the US.

Statement of age is required for:

  • All types of whisky aged less than 4 years
  • Grape lees brandy or grape pomace/grape marc brandy aged less than 2 years
  • Distilled spirits labeled with miscellaneous age references or representations
  • Distilled spirits labeled with a distillation date

Voluntary Labeling Standards:

If you choose to declare major food allergen voluntarily, Part 5 mandates that all major food allergens are declared on the label.

With that we have covered most of Part 5 regulations pertaining to label requirements for distilled spirits. Next up in this series we will analyze label requirements related to Beer and Malt Beverages.

Courtesy: Aravind Ravi, Technical Documentation Manager at ManageArtworks.

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