Alcohol FAQs

The U.S. Department of Agriculture (USDA) organic regulations create standards for the production, handling, processing, labeling, and marketing of all organically produced agricultural products. The regulations also create four labeling categories and identify specific substances that cannot be used in the production of organically made products. To obtain more information about the National Organic Program and to view a full text of the regulations, please visit the National Organic Program Web site at https://www.ams.usda.gov/nop.

If a bottler or importer uses the word "Organic" in any fashion likely to be perceived as claiming that a product or anything associated with it is organically produced, contains organic ingredients, or was processed in an organic manner or facility, TTB will consider this an organic claim and apply the requirements of the USDA organic regulations at 7 CFR part 205.

The four labeling categories of the USDA organic regulations are as follows (with information pertinent to alcohol beverages):

• "100% Organic" contains only organic ingredients and processing aids with no chemically added sulfites.
• "Organic" contains at least 95% organic ingredients with no chemically added sulfites.
• "Made with Organic [Ingredients]" contains at least 70% organic ingredients and may contain up to 100 ppm of sulfites from sulfur dioxide.
• Products containing less than 70% organic ingredients and products that are not processed by a certified organic handling operation may only identify each organically produced ingredient in an ingredient statement.

The complete USDA organic composition and labeling requirements are fully described in 7 CFR Subpart D—Labels, Labeling and Market Information.

The information required depends on the circumstances. A majority of claims will require you to submit the Certifier/Accredited Certifying Agent (ACA) Preview.

• A.  For "100% organic" "organic" and "made with organic [ingredients]:

Certifier/ACA Preview – indicates that an Accredited Certifying Agent (ACA) has reviewed the applicant's label, reconciled it with the applicant's certification, and found the label to be in compliance with USDA organic regulations. The certifier/ACA Preview will show actual images of the labels along with a stamp or signature of the ACA.

• B.  For organic Ingredient statements:

Producer's/Crop Organic Certificate - certifies that the grapes, fruit, or other agricultural produce used in the product comply with the USDA organic regulations. A list of different grapes, fruits, crops, and the year of harvest may appear on the actual certificate or on an attached addendum.

The United States has an organic equivalence arrangement with the European Union (EU). Under the terms of this arrangement, wine imported from the EU with organic labeling must comply with the labeling requirements of the USDA organic regulations.

For wine labeled “organic,” an EU control body must verify that prohibited substances, such as sulfur dioxide or potassium metabisulphite, were not added to the wine. For wine labeled “made from organic grapes,” an EU control body must ensure that no prohibited substances are used, except there is an allowance for the use of sulfur dioxide. The EU control body must verify that the total sulfite concentration from sulfur dioxide does not exceed 100 parts per million. Nonagricultural substances not listed under 7 CFR 205.605 are prohibited in wine labeled “organic” or “made with organic grapes.”

The certifier/ACA preview must be submitted to TTB; this indicates that the EU control body has verified compliance with these terms of the EU-U.S. organic equivalence arrangement.

Organic certificate(s) submitted to TTB (if required- see Question 4) must be in English or have complete translation(s) attached.

Certifiers/ACAs are private, State, and foreign entities accredited by the USDA for certifying foreign and domestic organic crop, livestock, and handling operations to USDA organic standards. All labeling applicants that are certified organic handlers and intend to make an organic claim (other than in an ingredient statement) on an alcohol beverage must submit the label(s) to their certifier/ACA for review and approval prior to submission to TTB. The certifier/ACA Preview is a document that must show actual images of the exact labels along with a stamp or signature of the certifier/ACA to verify that the product label complies with the USDA organic regulations. The National Organic Program maintains a list of Accredited Certifying Agents on its Web site at: https://www.ams.usda.gov/services/organic-certification/certifying-agents.

The producers/handlers of alcohol products that will be imported into the United States are responsible for supplying copies of the required documents to the importer. The importer should request the documents from the handler or the producer's wholesale distributer for submission with your Certificate of Label Approval application.

To use "Made with Organically Grown [Ingredients]" on a label, you must submit a certifier/ACA preview.

• The USDA organic seal, or foreign equivalent, is not allowed.
• Use of non-organic grapes is not permitted.
• Sulfur dioxide is the only sulfiting agent allowed; total sulfite concentration must not exceed 100 ppm. Sulfite disclosure is required on the label.
• The disclosure of organic ingredients on the label must be in the form of a phrase such as "Made with Organic [specify your organic ingredients here].” Examples are: "Made with Organically Grown Grapes," "Made with Organic Grapes," "Made with Organic Grapes from Our Vineyard," or "Made with Organically Produced Grapes."
• A Certification Statement “Certified Organic by---” or a similar phrase must appear below the bottler or importer's name and address statement.

The statement, "Certified Organic by---" or a similar phrase followed by the name of the certifier/ACA must appear below the bottler or importer's name and address statement. The organic certification statement must appear under the importer's name and address on imported products if the foreign producer/bottler's information is not present. We will accept the certification statement beneath either the importer or the foreign producer/bottler's information when present on imported labels. The business address, Internet address, or telephone number of the certifying agent may be included on the label. Certifier/ACA acronyms are acceptable in certification statements; however, logos or seals alone do not fulfill this requirement.

The only organic claim that can be made on the label is in an ingredient statement to indicate which ingredients are organic. If the organically produced ingredients are identified in the ingredient statement, the product's percentage of organic contents may be displayed on the information panel (7 CFR § 205.305). Acceptable variations include "X% Organic" or "X% Organic ingredients."

No, the vintage date may change on an organic label without obtaining a new Certificate of Label Approval.

The lack of supporting documentation for organic claims creates the greatest delay in label processing. In a majority of situations, the certifier/ACA preview will satisfy the requirement. A second common mistake occurs when submitters do not closely check the supporting documents to ensure that information listed on the product corresponds to the associated paperwork. Expired documentation, documents citing the incorrect product, and date conflicts represent common reasons why applications are returned.

A description of specialized farming practices generally may appear on alcohol beverage labels as additional information provided it is truthful, accurate, specific, and does not conflict with, or in any manner qualify, mandatory labeling information. However, due to the constantly evolving nature of this field, TTB reserves the right to request clarification and documented verification of any graphics, seals, logos, definitions, or language appearing on labels. For instance, any label specifically stating that the producer is certified by an agricultural organization must have documented proof.

Terms that refer to the environmental impact of the process and packaging rather than the product itself are usually acceptable. These words and phrases may not modify mandatory information on brand labels, but might appear as additional information after review on a case-by-case basis.