Orange wine has become one of the most talked-about categories in the modern wine world. Once considered niche, it now appears on wine lists ranging from natural wine bars to Michelin-starred restaurants. But despite its growing popularity, orange wine is often misunderstood.
So what exactly is orange wine—and how is it regulated under U.S. law?
What Is Orange Wine?
Contrary to what the name suggests, orange wine–as it is typically referenced and understood–is not made from oranges. It is also not necessarily made from orange-colored grapes.
Orange wine is produced from white wine grapes that are fermented with extended skin contact, similar to how red wines are made. Typically, white wine grapes are pressed and fermented without skins. With orange wine, the grape skins remain in contact with the juice for days, weeks, or even months.
This extended maceration gives the wine:
- A deeper amber or orange hue
- Tannins and structure typically associated with red wine
- More pronounced texture and oxidative or savory notes
In short, orange wine is a white wine made using techniques similar to red wine production.
Is “Orange Wine” a Legal Category?
In the United States, “orange wine” is not a formally defined regulatory category under federal law with respect to grape wine. In fact, if the term “orange wine” is used on a wine label, The Alcohol and Tobacco Tax and Trade Bureau (“TTB”) generally considers it to be wine made from actual oranges.
Orange wine produced from grapes is typically labeled as:
- A varietal wine (e.g., “Ribolla Gialla”)
- Or simply as “white wine” or “table wine”
The term “orange” may appear on a label as additional information, but it does not replace required class and type designations.
Labeling Considerations for Orange Wine
Because orange wine falls within existing grape wine classifications, it must still comply with all standard TTB requirements, including:
- Certificate of Label Approval (“COLA”) approval prior to interstate commerce (for wines at or above 7% ABV)
- Proper appellation rules if an AVA is listed
- Varietal composition thresholds (e.g., 75% minimum for most varietals) if a grape varietal is listed
- Mandatory Government Warning Statement
- Alcohol by volume (ABV) disclosure
Formula Approval—Is It Required for Orange Wine?
In most cases, orange wine made from standard white grapes using traditional fermentation techniques does not require formula approval.
However, formula approval may be required if:
- Non-grape ingredients are added
- Unusual processing methods are used
- Flavorings or botanicals are incorporated
- The wine does not conform to a standard grape wine classification*
* Not an exhaustive list.
Extended skin contact alone does not automatically trigger formula approval, but producers should evaluate the production method carefully.
Why It Matters
As consumer interest in alternative wine styles continues to grow, so does regulatory scrutiny. Producers and importers should ensure that:
- Labeling terminology is accurate and not misleading
- Required federal approvals are secured before bottling or importing
- Marketing claims align with regulatory classifications
While orange wine may challenge traditional expectations in the glass, it does not operate outside the regulatory framework.
How Lindsey Zahn P.C. Can Help with Your Orange Wine Product
As producers continue to innovate with styles like orange wine, ensuring regulatory compliance remains essential. From evaluating whether formula approval is required to preparing and securing COLA approvals, Lindsey Zahn, PC works with wineries, importers, and brand owners to navigate federal and state labeling requirements with confidence. Whether you are launching a new orange wine, expanding into new markets, or refining your label language and claims, we help ensure your product is both market-ready and compliant.
If you are considering launching an orange wine product or have questions about TTB requirements or compliance expectations, we encourage you to contact us to discuss your project.
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