How COLAClear's federal and state compliance checks for wine, spirits, and beer are derived, which regulations back each check, how the rule set is maintained, and where the underlying data comes from.
COLAClear pre-screens standard wine, spirits, and beer labels for compliance with federal U.S. labeling regulations and state-specific rule sets:
Out of scope: formula-dependent products requiring TTB formula approval (flavored wines and spirits, cordials, liqueurs, ready-to-drink cocktails, sake, flavored or specialty malt beverages including FMBs, hard seltzers, and flavored beers under 27 CFR 25.55), and wines under 7% alcohol by volume (which fall under FDA labeling jurisdiction rather than TTB).
State coverage in the active rule set: for wine and spirits, California (conjunctive labeling) and Oregon (varietal minimum). For beer, six states with meaningful divergence from federal — Pennsylvania, New York, Texas, Massachusetts, California, and Oregon — covering mandatory ABV display, bottle-bill deposit markings, and state product registration reminders. Tier 3 documentation reminders additionally include state-specific items (such as Virginia's state registration fee and 21% ABV cap for wine) where federal or state authorities impose requirements not verifiable from the label artwork itself.
The 34 checks are organized into two confidence tiers based on how definitively the compliance question can be answered from the label text alone. A third companion category — Documentation Reminders — surfaces 9 additional items TTB requires that can't be verified from the label image, so they aren't counted toward the 34 but are listed here for completeness.
Tier 1 — Automated Pass / FailDeterministic text-matching and pattern-validation. OCR extracts the label text; the rules engine evaluates it against fixed regulatory requirements. Binary outcomes.
| Check | Description | CFR Citation |
|---|---|---|
| Brand name present | Brand label must include the brand name. | 27 CFR 4.30, 5.62 |
| Class/type designation | Validated against TTB's enumerated list of authorized class/type designations. | 27 CFR 4.34, 5.63 |
| Alcohol content format | ABV stated correctly with tolerance validation. | 27 CFR 4.36, 5.65 |
| Proof–ABV consistency | For spirits: proof must equal 2× ABV. | 27 CFR 5.65(a) |
| Net contents | Required statement present in metric format. | 27 CFR 4.37, 5.67 |
| Standards of fill | Net contents value validated against the list of TTB-authorized bottle sizes for wine and distilled spirits. | 27 CFR 4.72, 5.203 |
| Name and address of bottler/producer/importer | With qualifying phrase. | 27 CFR 4.35, 5.66 |
| Government health warning | All five mandatory components present (warning header, Surgeon General reference, pregnancy/birth defects clause, machinery clause, health-impairment clause). | 27 CFR Part 16 |
| Health warning — exact wording | Verbatim text match against the eleven canonical phrases of the mandatory warning, with one-token OCR tolerance. | 27 CFR 16.21 |
| Sulfite declaration | Required when applicable. | 27 CFR 4.32(e) |
| Country of origin (imports) | "Product of [Country]" required. | 27 CFR 4.35(d), 5.66(d) |
| Imported by statement | Importer entity name and address required for imports. | 27 CFR 4.35(b), 5.66(b) |
| Protected geographic designation | Cross-validation of geographic designations against country of origin. | 27 CFR 5.152 |
| Bottled in Bond | If claimed: must be exactly 100 proof (50% ABV), with Distilled Spirits Plant (DSP) number. | 27 CFR 5.88 |
| Prohibited keyword scan | Flags health claims and therapeutic language. | 27 CFR 4.39(h), 5.81 |
| Check | Description | CFR Citation |
|---|---|---|
| Vintage date format | Co-occurrence with appellation required. | 27 CFR 4.27 |
| Flavored spirits format | [Flavor] Flavored [Base Spirit] designation format. | 27 CFR 5.155 |
| English language requirement | Mandatory information must appear in English; additional languages may appear alongside without replacing the English version. | 27 CFR 4.30, 5.63 |
| Color additive / allergen declarations | FD&C Yellow #5, cochineal/carmine, and similar. | 27 CFR 4.32(f), 5.63(a)(8) |
| Saccharin / aspartame warnings | Required if present. | 27 CFR 5.63(a)(6)–(7) |
| Agave spirits origin validation | "Agave Spirits" cannot also be designated as Tequila or Mezcal unless from Mexico. | 27 CFR 5.147 |
| Straight whisky + caramel color | Inconsistency detection: straight whiskies cannot list caramel color as an additive. | 27 CFR 5.143, 5.155 |
| Check | Description | Source |
|---|---|---|
| California conjunctive labeling | If a wine names a sub-appellation (Rutherford, Stags Leap District, etc.), the parent appellation (e.g., Napa Valley) must also appear on the label. Applies to approximately 50 California sub-AVAs. | California Business and Professions Code |
| Oregon varietal minimum | Wines bearing an Oregon appellation must contain at least 90% of the named grape variety (federal is 75%). Eighteen grape varieties — including Cabernet Sauvignon, Merlot, Syrah, and Zinfandel — follow the federal 75% rule. | Oregon Administrative Rules 845-010-0915 |
These identify potential issues that require human judgment to resolve. The system flags the issue; the user makes the determination.
| Check | Description | CFR Citation |
|---|---|---|
| Brand name misleadingness | Geographic terms in the brand name cross-referenced against the AVA / appellation database. | 27 CFR 4.39, 5.81 |
| Minimum type size compliance | Pixel-to-millimeter conversion using image DPI and declared container size. | 27 CFR 4.38, 5.68 |
| Legibility / contrast | Foreground–background color ratio analysis. | 27 CFR 4.31, 5.61 |
| Appellation of origin validity | Checked against TTB Part 9 AVA registry (279 approved AVAs as of 2025). | 27 CFR Part 9 |
| Grape varietal name validity | Checked against the TTB-approved variety list. | 27 CFR 4.23 |
| Permit validity | Bottler / importer entity name cross-referenced against TTB's online permit database. | — |
| Organic claims | Flagged for USDA National Organic Program (NOP) certification verification. | — |
| Estate Bottled | Co-occurrence with an AVA designation required. | 27 CFR 4.26 |
| Age statement adequacy | Straight whisky under four years old must declare age. | 27 CFR 5.74 |
| Subjective misleadingness | "Reserve," "Special," "Limited Edition," "Natural," and sustainability claims flagged for review. | 27 CFR 4.39, 5.81 |
These items are required by TTB or state authorities but cannot be verified from the label image. The system generates reminders so the user has supporting documentation ready.
| Reminder | Description | Citation |
|---|---|---|
| Grape sourcing percentage | For appellation claims: 75% for state/county, 85% for AVA. | 27 CFR 4.25 |
| Varietal percentage | 75% federal minimum; 85% or 90% Oregon depending on grape variety. | 27 CFR 4.23 |
| Spirit age in barrel | Actual age for age statements. | 27 CFR 5.74 |
| Mashbill composition | The grain recipe: for bourbon, 51% corn; for rye, 51% rye; etc. | 27 CFR 5.143 |
| Fermentation / distillation by named entity | If the label states "Produced by" or "Distilled by," documentation required. | 27 CFR 4.35, 5.66 |
| Vineyard ownership / control | Required for Estate Bottled claims. | 27 CFR 4.26 |
| California appellation sourcing | 100% of grapes must be from California (stricter than federal 75–85%). | California rules |
| Virginia state registration | $30 fee required in addition to the federal COLA. | Virginia ABC |
| Virginia wine ABV | Must not exceed 21% alcohol by volume. | Virginia ABC |
Primary sources. The rule set is maintained against current 27 CFR text as published by the Electronic Code of Federal Regulations (eCFR), which is the official online source for the Code of Federal Regulations. When a rule is added, modified, or removed in eCFR, the corresponding check is updated in COLAClear.
Secondary sources. TTB rulings, industry circulars, TTB.gov labeling resources, and Federal Register notices are monitored for guidance that affects label requirements. These sources clarify how TTB interprets specific rules in practice.
Update cadence. Regulatory changes to 27 CFR Parts 4, 5, and 16 are typically infrequent — a few substantive changes per year. When a change is published, the rule set and this documentation are updated. Non-regulatory changes (adding AVAs to the validation list, for example) happen as new designations are issued by TTB.
State coverage. California and Oregon are covered because their labeling requirements differ meaningfully from federal standards. Other states largely follow federal TTB rules with minor procedural additions (registration fees, resale certifications). Additional state coverage will be added based on customer demand.
OCR validation. The optical character recognition engine (Google Cloud Vision) was tested on 24 real label artwork files from three producers — Minden Mill Distilling (bourbon, rye, American single malt), Pine Ridge Vineyards (Cabernet Sauvignon, Sauvignon Blanc, Chenin Blanc Viognier), and Two Stacks Irish Whiskey (100ml cans). Confidence scores ranged from 80% to 99%. All mandatory text elements that the rules engine relies on — health warning, alcohol content, name and address, class/type designation — were extracted in usable form from every label tested.
Rule accuracy. Each check is grounded in a specific CFR section, a specific California code reference, or a specific Oregon Administrative Rule. The rule set does not rely on case law interpretation, regulatory inference, or LLM-generated content. The compliance engine is deterministic: same label in, same result out.
Feedback loop. The application invites users to report TTB outcomes after they submit their own labels (approved or rejected, with reasons). These reports are used to identify false positives (the rules engine flagged an issue TTB accepted) and false negatives (the rules engine missed an issue TTB caught). The feedback loop is the mechanism by which the rule set improves over time.
Industry statistics cited on this site are derived from the TTB Public COLA Registry accessed via the COLA Cloud API, which provides programmatic access to the same data as TTB's COLAs Online public search.
Specifically: analysis of 104,196 wine and distilled spirits COLAs approved January–December 2025 is the basis for the median filings per permit holder, small-filer percentages, and addressable market size referenced on the homepage. Median TTB processing time is sourced directly from TTB's published statistics. The raw dataset includes permit number, product type, brand name, product name, approval date, origin, domestic/imported status, and class/type. Analysis methodology is available on request.
COLAClear does not replace attorney review and is not a guarantee of TTB approval. Specifically:
For unusual, complex, or borderline labels, we recommend pairing COLAClear with review by a qualified beverage compliance attorney.