The net contents statement indicates the volume of distilled spirits in the container on which the label appears, expressed in Liters and milliliters. The word “liter” may be alternatively spelled “litre” or may be abbreviated as “L”. The word “milliliters” may be abbreviated as “ml.,” “mL.,” or “ML.”
On the label example above, “750 mL” is the net contents.
Where should the net contents statement be placed on the product?
The net contents statement may appear on any label (on the front, back, or side of the container).
The net contents statement may be blown, embossed, or molded into the container as part of the process of manufacturing the container.
What are the formatting requirements for the net contents statement?
The net contents of distilled spirits for which a “standard of fill” is prescribed in 27 CFR 5.203 must be stated in the same manner and form as set forth in this standard of fill regulation.
Type size:
- Minimum 2 mm for containers larger than 200mL,
- Minimum 1 mm for containers of 200mL or less
NOTE: The minimum type size applies to each numeral or letter in the statement, including both upper-case and lower-case letters.
Legibility:
- Must generally appear parallel to the base of the container; or shall be otherwise equally conspicuous
- Must be readily legible;
- Must appear on a contrasting background; and
- Must appear separate and apart from, or be substantially more conspicuous than, descriptive or explanatory information.
Does the net contents statement need to indicate the contents of the container exactly, or does TTB allow a tolerance?
- TTB allows the following tolerances:
- Discrepancies due to errors in measuring which occur in filling conducted in compliance with good commercial practice.
- Discrepancies due to differences in the capacity of containers, resulting solely from unavoidable difficulties in manufacturing such containers to a uniform capacity. However, no greater tolerance shall be allowed in case of containers which, because of their design, cannot be made of approximately uniform capacity.
- Discrepancies in measure due to differences in atmospheric conditions in various places and which result from the ordinary and customary exposure of alcohol beverages in containers to evaporation. The reasonableness of discrepancies under this paragraph shall be determined on the facts in each case.
What requirements apply to standard distilled spirits containers?
A standard distilled spirits container must be made and filled so as to not mislead purchasers. Unless a distilled spirits container has been approved by TTB as a distinctive liquor container, TTB finds that:
- Headspace: A liquor container with a capacity of 200 mL or more misleads purchasers if it has a headspace in excess of 8 percent of the total capacity of the container after closure.
- Design: A liquor container misleads purchasers (irrespective of the correctness of the stated net contents) if it is made and formed in such a way that its actual capacity is substantially less than the capacity it appears to have upon visual examination under ordinary conditions of purchase or use.
What are the authorized standards of fill?
For containers other than the cans described below:
| 1.8 Liters | 700 mL |
| 1.75 Liters | 500 mL (Authorized for bottling until June 30, 1989) |
| 1 Liter | 375 mL |
| 900 mL | 200 mL |
| 750 mL | 100 mL |
| 720 mL | 50 mL |
Cans: For metal containers which have the general shape and design of a can, which have a closure which is an integral part of the container, and which cannot be readily reclosed after opening:
| 355 mL |
| 200 mL |
| 100 mL |
| 50 mL |
May I use U.S. equivalent measurements in addition to a metric net contents statement?
Yes, the equivalent standard U.S. measure may also be stated on the container in addition to the metric measure but, if used, it must appear in the same field of vision as the metric net contents statement.
As of December 22, 2022: this document was updated for purposes of T.D. TTB-176, Modernization of the Labeling and Advertising Regulations for Distilled Spirits and Malt Beverages.