FDA Wine Labeling Requirements for Low-Alcohol Wines - Lindsey Zahn P.C.

When most people think about wine labeling requirements in the United States, the Alcohol and Tobacco Tax and Trade Bureau (“TTB”) typically comes to mind. For the majority of wines sold in the U.S., this is correct—the TTB regulates labeling and advertising for wines containing 7% alcohol by volume (“ABV”) or more.

However, wines with an ABV of less than 7% fall under a different regulatory scheme. In these cases, the U.S. Food and Drug Administration (“FDA”), not the TTB, has primary jurisdiction over the label. This often surprises brand owners and can create compliance challenges for low-alcohol products, such as wine spritzers, certain sparkling wines, and some wine-based beverages.

*Image credit: Jonathan Kemper from Unsplash*

Who Regulates What?

TTB – Wines ≥ 7% ABV (label approval through COLAs, specific wine class/type designations, health warning statement, etc.).
FDA – Wines < 7% ABV (label governed by FDA food labeling rules, no COLA requirement, but subject to mandatory FDA nutrition and ingredient labeling).

Key FDA Labeling Requirements for Low-Alcohol Wines

If your wine is under 7% ABV, your label must comply with the FDA’s food labeling regulations, which differ significantly from TTB rules. Here are the major elements to consider:

1. Statement of Identity

The label must clearly identify the product as “wine” or another truthful, non-misleading term that accurately describes the beverage. The product name must not imply characteristics it does not have.

2. Net Contents

You must declare the volume of the container (e.g., “750 mL”) on the principal display panel, using both U.S. customary units and, where applicable, metric units.

3. Name and Place of Business

Include the name and address of the manufacturer, packer, or distributor. If you use a “packed for” or “distributed by” statement, ensure it follows FDA format.

4. Nutrition Facts Panel

Unlike most TTB-regulated wines, FDA-regulated low-alcohol wines are generally required to display a Nutrition Facts Panel. This includes serving size, calories, total carbohydrates, sugars, protein, and other required nutrients and vitamins.

5. Ingredients Statement

An ingredient list is required, showing each ingredient in descending order of predominance by weight. This often includes wine, water, sugar, natural flavors, acids, and preservatives (if applicable).

6. Allergen Labeling

If your product contains any of the FDA’s “major food allergens” (e.g., milk, eggs, fish, tree nuts, wheat), an allergen statement must be included on the label.

7. Alcohol Content Statement

You must list the alcohol content, typically in the format “ ___% alcohol by volume.” This typically should be readily legible and on a contrasting background.

8. Other Labeling Claims

Any claims such as “low calorie,” “organic,” or “gluten-free” must meet FDA substantiation and formatting rules. Misleading or unverified claims can trigger enforcement.

Why This Matters for Brand Owners

The FDA’s labeling requirements are more closely aligned with packaged food products than with traditional wine labels. For producers who are accustomed to the TTB process, this shift can create compliance pitfalls—especially if your portfolio includes both low- and standard-alcohol wines.

Failure to comply can result in label change demands, product holds, or enforcement actions. For brand owners, this means label development should start with a clear understanding of which agency regulates the product.

Low-alcohol wines have become increasingly popular with health-conscious consumers and those seeking lighter drinking options. But before you launch a low-ABV product, you must ensure your labels meet FDA requirements—which differ significantly from TTB rules.

Below is a breakdown of FDA labeling requirements for low-alcohol wines:

FDA Labeling Requirements for Low-Alcohol Wines (<7% ABV)

Label Element	Required?	Details / Notes
Statement of Identity	✅	Must use a truthful and non-misleading statement describing the product (e.g., “low alcohol grape wine” or “wine specialty beverage”).
Net Quantity of Contents	✅	Must list the volume in U.S. and metric units (e.g., “750 mL (25.4 fl oz)”).
Name and Place of Business	✅	Must list the responsible party’s name and address (manufacturer, packer, or distributor).
Ingredient Statement	✅	All ingredients must be listed in descending order by weight.
Allergen Labeling	✅	Common allergens (e.g., sulfites, milk, eggs, wheat) must be declared.
Nutrition Facts Panel	✅	Required in the standard Nutrition Facts format, including serving size, calories, sugar, carbs, etc.
Alcohol Content	✅	Must list ABV as a percentage (e.g., “Contains 5% Alcohol by Volume”).
Health Warning Statement	✅	The TTB-required government health warning is required for wines under 7% ABV regulated by the FDA.
Claims (e.g., “low sugar”)	Conditional	Must comply with FDA nutrition labeling regulations and be truthful, not misleading.
Date/Code Marking	✅ (if perishable)	If shelf life is limited, the “Best By” or “Use By” date may be required.

Key Compliance Tips

Don’t assume TTB rules apply — FDA requirements differ, especially regarding ingredient and nutrition labeling.
Double-check serving sizes — Serving size rules are dictated by FDA food labeling laws, not by standard 5 oz wine pours.
Be careful with claims — “Low sugar,” “natural,” or “organic” claims must meet specific FDA criteria to avoid enforcement action.
Ingredient transparency matters — Since an ingredient list is required, all flavorings, sweeteners, and additives must be disclosed.

How We Can Help

At Lindsey Zahn P.C., we help wineries, importers, and beverage companies navigate both TTB and FDA labeling rules. Whether you are developing a new low-alcohol wine or reviewing an existing label for compliance, we can provide detailed guidance to ensure your product meets all federal requirements before it goes to market.

📩 Email us at info@zahnlawpc.com
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