TTB has added six new allowable revisions (to the existing 28) to alcohol beverage labels. To streamline the COLA approval process, TTB allows for certain changes to be made to labels without subject to a new COLA approval.
Of particular significance to wineries is the new revisions allowed for the disclosure of sulfites. According to the Industry Circular issued today wineries may now, ” change an approved sulfite statement to any of these options: “Change an approved sulfite statement to any of these options: “Contains Sulfites,” “Contains (a) Sulfiting Agent(s),” “Contains [name of specific sulfating agent],”“Contains Naturally Occurring and Added Sulfites,” or “Contains Naturally Occurring Sulfites.” Additionally, “sulphites” may be used in lieu of “sulfites”.
A sulfite statement is required when sulfur dioxide or a sulfiting agent is detected at a level of 10 or more parts per million, measured as total sulfur dioxide. The statement used must accurately reflect all of the sulfur dioxide or sulfiting agent(s) present in the alcohol beverage. For wine: Any other variation of the statement or removal of the statement requires a lab analysis. For sulfite waivers, the proprietor must have proof of sample analysis from a TTB-certified laboratory or from the TTB Compliance Laboratory.
For more information please refer to the Industry Circular: http://www.ttb.gov/industry_circulars/archives/2014/14-02.html
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