DISTILLED SPIRITS LABELS: LABELING REQUIREMENTS WITH RESPECT TO
METRIC STANDARDS OF FILL
Proprietors of Distilled Spirits Plants, Manufacturers of Liquor
Bottles, Wholesale Liquor Dealers, Importers and Others Concerned:
PURPOSE. The purpose of this circular is two-fold:
1. To remind industry members that, in accordance with 27 CFR 5.47a,
the effective date for conformity with metric standards of fill for
distilled spirits is January 1, 1980; and,
2. To advise industry members that labels which have been approved
for use on containers for distilled spirits may not require new
certificates of label approval or certificates of exemption from
label approval when revised only to bring into conformity with metric
standards of fill as required by 27 CFR 5.47a.
Metric Standards of Fill. To avoid any misunderstanding, this circular
is intended to make it clear that the provisions of 27 CFR 5.47a,
relating to metric standards of fill for distilled spirits, will be
applied, without exception, after December 31, 1979. The metric
standards of fill in 27 CFR 5.47a apply to all distilled spirits, including cordials and liqueurs, cocktails, highballs, bitters and
In accordance with 27 CFR 5.53, distilled spirits imported in original
containers not conforming to metric standards of fill shall not be
released from customs custody after December 31, 1979, unless the
distilled spirits are being withdrawn from a customs bonded warehouse
into which they were entered on or before December 31, 1979; or unless
they are accompanied by a statement certifying that they were bottled
or packed prior to January 1, 1980. This statement may be signed by
any official authorized by the appropriate foreign government to
issue such certification.
After December 31, 1979, containers for distilled spirits may bear
statements of net contents in addition to the required metric net
content statement provided such optional statements represent an
equivalent volume and are not in any way misleading to the consumer.
Additional statements of net contents may appear separate and apart
from, rather than in direct conjunction with, the required metric
net content statement but may not be more conspicuous than the re-
quired statement. For example, if a distilled spirits container
shows the net contents in accordance with 27 CFR 5.47a as "750 ml,"
an additional statement such as "75 cl," ".75 L," "25.4 fl. oz.,"
etc., may appear anywhere on the container provided its appearance is
not more conspicuous than the required "750 ml," nor is in any other
manner misleading to the consumer.
Labels Changed to Conform with Metric Standards of Fill. New certif-
icates of label approval or certificates of exemption from label
approval are not required for previously approved labels being
changed only to comply with metric standards of fill for distilled
spirits as required by 27 CFR 5.47a.
Such changes are limited to the substitution of the required metric
net content statement in lieu of nonmetric net content statements,
the addition of optional net content statements as described above,
and the deletion of nonmetric net content statements including, after
December 31, 1979, those required under 27 CFR 5.38. Such changes
will not require resubmission for label approval provided they are
not misleading to the consumer or result in the rearrangement,
obliteration, obscuration, or any other revision of mandatory infor-
mation required under the Federal Alcohol Administration Act.
Inquiries. Inquiries concerning this circular should refer to its
number and be addressed to the Assistant Director (Regulatory
Enforcement), Bureau of Alcohol, Tobacco and Firearms, 1200 Pennsyl-
vania Avenue, NW, Washington, DC 20226.