ATF Ruling 74-25

The Bureau of Alcohol, Tobacco and Firearms has had occasion to re-examine its labeling requirements
concerning certain type designations of grape wines.

The provisions of 27 CFR 4.23, which implement, in part, the provisions of 27 U.S.C. 205(e), provide that a name indicative of a variety of grape may be employed as the type designation of a grape wine if the wine derives its predominant taste, aroma, and characteristics, and at least 51 percent of its volume, from that variety of grape.

Possible consumer deception has resulted from the fact that less costly grape varietals have been used in wines which, by their type designations, indicate that the wine was produced from more expensive varietals. For example, Ruby Cabernet and Cabernet Franc are being used in the production of wines ultimately labeled and sold as Cabernet. The word Cabernet has been approved over the years as the name of a grape variety suitable for wine designation purposes and was generally recognized as being synonymous with the complete name of Cabernet Sauvignon. However, the development of new varieties of grapes within the Cabernet family, such as Ruby Cabernet, has detracted from the formerly recognized distinction of the term. In other words, our former position was based on the fact that Cabernet was another name for Cabernet Sauvignon, and if a wine derived not less than 51 percent of its volume from Cabernet Sauvignon grapes, it was considered to be properly designated as either Cabernet or Cabernet Sauvignon.

Held, that winemakers may continue to use the designation Cabernet as a type designation for grape wines under the provisions of 27 CFR 4.23 without additional designation as to specific variety. However, on and after April 1, 1975, the use of the designation Cabernet will be restricted to wines which derive not less than 51 percent of their volume from Cabernet Sauvignon grapes. The designations Cabernet Sauvignon, Ruby Cabernet and Cabernet Franc are valid designations for wines which derive their predominant taste, aroma, and characteristics, and at least 51 percent of their volume, from Cabernet Sauvignon, Ruby Cabernet, or Cabernet Franc grapes, respectively.

27 CFR 4.23