Your Guide to TTB Requirements for Organic Alcoholic Beverage Labels

There are already lots of regulations to follow with food and beverages in the U.S., and alcoholic beverages have even more hoops to jump through because of the Alcohol and Tobacco Tax and Trade Bureau (TTB). The TTB is part of the U.S. Department of Treasury, an entity that regulates the trade and import of alcohol, tobacco, and firearms.

One area regulated by the TTB is the use of the term “organic” on alcoholic beverage labels. Many brands earn and desire this designation on their beverage products so they’re more appealing to some consumers, as organic can have positive connotations about how the drink was sourced and manufactured. The TTB also enforces regulations about disclosing sulfite contents on wine labels.

The TTB requires that, on top of other guidelines, alcoholic beverage labels go through a review process called Certificate of Label Approval (COLA), which is linked to a database that provides information on COLAs that are approved or expired.

There’s a lot more to learn beyond getting COLA approval for organic products. This is your guide to TTB organic labeling requirements and the other agencies you may come across in the process of certifying your organic alcoholic beverages.

Other Agencies Involved in Organic Labeling

The TTB did not create regulations surrounding organic products. The U.S. Department of Agriculture (USDA) created rules under the National Organic Program (NOP) about how brands and those involved in the production process can claim that something is organic. The TTB works with the USDA on ensuring beverage makers follow the regulations on alcoholic beverages. Here is a breakdown of the different agencies you may need to know about:

The USDA

The USDA is a large governmental umbrella organization for 29 agencies that create and enforce laws related to food, natural resources, rural development, nutrition, and other related concerns.

The NOP

This is a federal program that enforces the requirements specifically for organic products sold in the U.S. They enforce the guidelines and also work with third parties to certify farms and businesses.

The AMS

The Agricultural Marketing Service (AMS) is part of the USDA and initiates marketing opportunities for organizations that produce food, fiber, and specialty crops, according to the AMS website. The AMS has also created requirements for organic alcoholic beverage claims.

Note that this guide will only cover general requirements from the TTB, but it’s wise to explore any AMS guidelines as well, so you know you’re in compliance.

8 FAQs About Organic Labeling on Alcoholic Beverages

The laws surrounding labels for organic alcoholic beverages can be complicated and hard to follow. Here are a few frequently asked questions to make it easier to break down how it all works:

1. What Is an Organic Claim?

An organic claim is when a company indicates that a product contains organic ingredients or was processed using organic practices, according to the TTB.

2. What Types of Organic Claims Are There?

Here are the four key labeling categories contained in the USDA regulations that cover alcoholic drinks:

• “100% Organic” means the alcoholic product contacts only organic ingredients, and there are no chemically added sulfites.
• Claiming that a drink is “Organic” means there are at least 95% organic ingredients and no added sulfites.
• A product can earn the label “Made with Organic Ingredients”  if there are at least 70% organic ingredients in the product, and it could contain a maximum of 100ppm of sulfites.
• A product qualifies for the label “Very Little Organic Ingredients” if it has less than 70% organic ingredients. It can only make an organic claim about each applicable organic ingredient if it’s not processed by a certified organic handler.

3. What If an Alcoholic Drink Contains Added Sulfites?

A wine that contains added sulfites can only claim the Made With Organic Ingredients category. This is a TTB requirement on top of the standard USDA organic requirements. (All wine labels must declare that the product “contains sulfites” or sulfiting agents if the drink contains more than 10 or more parts per million of the additive.)

4. What Is the USDA Organic Seal?

The USDA provides its official organic seal to mark products that meet organic standards. Producers that include the seal while knowingly failing to meet USDA standards may face steep penalties, so you always need to ensure you’re using it properly.

5. Who Approves Certification?

Certifiers/ACAs are accredited entities that can certify organic processes and materials to USDA standards. Certified organic handlers need to submit their labels to a certifier/ACA for review before making an organic claim. This is known as a Certifier/ACA Preview, which confirms that the label is compliant with standards. 

This process is required for both 100% organic and organic claims. To make claims about organic ingredients, applicants need a Producer’s/Crop Organic Certificate, which indicates that the produce included in the product is certified organic.

6. What Is a Certified Organic Handler?

Certified organic handlers have organic certificates and have gone through the process of contacting an NOP certification body, applying, and undergoing a facility inspection.

7. What Needs to Appear on a Label of an Organic Alcoholic Beverage?

The following phrase needs to appear under the name of the bottler or importer on the label: “Certified Organic by [name of the certifier/ACA].”

8. When Can I Include the USDA Organic Seal?

Products that are 100% organic or organic can include the USDA Organic Seal, but not products that are just made with organic ingredients.