Blog  /  May 7, 2026

7 reasons TTB issues a “Needs Correction” notice on wine labels

By Zillah Bahar, Founder

Before COLAClear, I worked as an ecommerce content specialist managing wine SKUs in Salsify — a product information platform distributors and retailers use to organize product images and descriptions across sales channels. Every wine I onboarded had a COLA tied to it. I saw firsthand how often a single labeling error rippled downstream into product pages, distributor catalogs, and corrected listings.

That’s what made me build COLAClear: producers shouldn’t be caught off-guard by errors that are catchable before TTB ever sees the label.

These seven issues come up most often in our pre-screens, and they map to the patterns TTB consistently flags on submitted labels:

1. Government Health Warning errors

(27 CFR Part 16) The single most common rejection. The warning has five mandatory components — the “GOVERNMENT WARNING:” header, the Surgeon General reference, pregnancy/birth defects, machinery/operation, and health problems language. Missing a piece, paraphrased wording, or text below minimum size triggers a correction.

2. Sulfite declaration missing or wrong

(27 CFR 4.32(e)) Required for any wine with 10+ ppm sulfites — most wines. Must read “Contains Sulfites” or equivalent. Designers sometimes drop it during a label refresh.

3. Missing varietal percentages on multi-varietal labels

(27 CFR 4.23(b)) If your label names two or more grape varieties, each needs a percentage of the blend disclosed. Listing “Cabernet Sauvignon, Petite Sirah, Teroldego” without percentages fails.

4. Vintage date without an appellation

(27 CFR 4.27) You can’t list a vintage year unless your label also identifies an appellation of origin. A vintage on its own — no AVA, no state, no county — gets flagged.

5. Brand name with a geographic term that’s misleading

(27 CFR 4.39) A brand name suggesting an origin you don’t qualify for needs a disclaimer. “Napa” on a wine sourced from Lodi is a problem.

6. Class/type designation that doesn’t match the product

(27 CFR 4.34) Calling a fortified wine “Sherry” when it’s not from Jerez, or labeling a fruit wine as “wine” without qualification. The designation has to match what’s in the bottle.

7. Producer/bottler statement missing or wrong

(27 CFR 4.35) “Produced and Bottled by [Name], [City], [State]” needs to appear on the label, and the named entity must hold a valid TTB permit. Common failure: the statement is on the back label but the entity name is incomplete.

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