Jason Guillard
Journal

What has to go on a spirits label

Every spirits label sold in the U.S. needs a brand name, the type of spirit, the alcohol content, the net contents, a name and address, and the government health warning. Some bottles also need an age statement or a color disclosure, and imports need a country of origin.

That's the short version. Below is what each item means in practice and what it changes about the design, because most of these rules decide where things go and how small they can be. I'm a packaging designer, not a lawyer, so treat this as a plain guide to the federal rules, not legal advice. The source for everything here is the TTB's distilled spirits labeling pages, and those are what to check before you print.

The checklist

ItemWhat it isSmallest size
Brand nameThe name the spirit is sold under—
Class or typeWhat the spirit is, such as vodka, rum, or bourbon whisky—
Alcohol contentPercent alcohol by volume2 mm
Net contentsHow much is in the bottle, in milliliters or liters2 mm
Name and addressWho bottled or imported it, with city and state2 mm
Health warningThe government warning, word for word2 mm
Age statementOnly for some spirits, depending on type and age—
Color disclosureOnly if certain colors are used2 mm
Country of originImports only—

Sizes are for bottles over 200 mL, or for the health warning, over 237 mL. Smaller bottles have smaller minimums, covered below. TTB's mandatory information checklist is worth printing out.

Three things that have to sit together

The brand name, the type of spirit, and the alcohol content must all be visible at once, without turning the bottle. TTB calls this the same field of vision, and on a round bottle it means within 40 percent of the way around (source).

This is the rule that shapes the front of the label more than any other. A beautiful front with the alcohol content tucked onto the back won't pass. Plan for these three to share one face from the first sketch.

Alcohol content

  • Write it as percent alcohol by volume, for example "40% Alc. by Vol."
  • "Alc." and "Vol." are the only allowed abbreviations. "ABV" isn't allowed.
  • Proof is optional, but only alongside the percentage, set off in parentheses or similar.
  • The real number can be off by 0.3 percentage points either way.

From TTB's page on alcohol content.

Net contents

State the amount in milliliters or liters. Spirits come in set sizes, including 50 mL, 200 mL, 375 mL, 700 mL, 750 mL, 1 L, 1.75 L, and 1.8 L, among others. Ounces are optional, and if you include them, they go in the same field of vision as the metric amount. The amount can also be molded into the glass instead of printed (source).

Name and address

This says who made or brought the spirit in, with a phrase like "Distilled by," "Bottled by," or "Imported by," followed by the name on the company's permit and the city and state. A street address isn't required. It can go on any label on the bottle (source).

The health warning

Every bottle needs the government warning about drinking during pregnancy and impaired driving. Copy the exact wording from TTB's health warning page. Don't retype it from memory or another bottle.

  • "GOVERNMENT WARNING" in capitals and bold. The rest isn't bold.
  • One continuous paragraph, separate from everything else.
  • At least 2 mm tall on bottles over 237 mL up to 3 liters, and 1 mm on 237 mL or less.
  • No more than 25 characters per inch at 2 mm, or 40 per inch at 1 mm, so it can't be squeezed into a sliver.
  • Front, back, or side, on a background that contrasts with it.

The character limit is what catches people. On a narrow label, the warning takes more room than expected, so it needs space reserved early.

Color and age

If a spirit contains FD&C Yellow No. 5, cochineal extract, or carmine, the label has to name it, for example "Contains FD&C Yellow No. 5" (source). Some spirits also need an age statement depending on their type and how long they've been aged. Whiskies aged under four years are the most common case. Check the rules for your spirit's type before the copy is final.

Label approval

Before a spirit can be sold across state lines, the bottler or importer needs a certificate of label approval, called a COLA, from TTB. Domestic bottlers need it before bottling, and importers before the product leaves customs. Applying is free, and approval often takes less than a week when nothing needs fixing. Spirits with added flavors or colors may need their formula approved first. If you'll only ever sell in the state where you bottle, you may qualify for a certificate of exemption instead. State rules are separate (source).

What this means for the design

  • Design the back label at the same time as the front. Legal copy decides how much room is left for everything else.
  • Get final copy before design starts. A late change to the alcohol content or the warning means reworking the layout.
  • Design for the smallest bottle. If you'll sell 50 mL minis, the same information has to fit there at 1 mm.
  • Keep required text off busy art. Contrast is part of the rule, not just good taste.
  • Read it from across the room. A spirit spends its life on a back bar. The name and type should read from a few feet away, even in low light. More in what a bartender needs from a bottle.

Common mistakes

  • Writing "ABV."
  • Showing proof without the percentage beside it.
  • Putting the alcohol content on a different side from the brand name.
  • Bolding the whole warning, or breaking it into lines with other text in between.
  • Squeezing the warning past the character limit to make it fit.

Questions

Do canned cocktails follow these rules?

It depends on what's in the can. A cocktail made with distilled spirits generally follows the spirits rules. One made with a malt or wine base follows the rules for that category instead. Confirm the category before design starts, because it changes what has to be on the can.

Does the designer file for label approval?

Usually not. The bottler or importer applies, often with help from a compliance consultant. The designer's job is to make sure everything required fits, at the right size, in the right place.

Do I still need to check state rules?

Yes. Federal approval covers federal requirements. States can have their own, so check with the states where you plan to sell.

What about non-alcoholic syrups and mixers?

Products under 0.5% alcohol aren't covered by these spirits rules. Syrups and mixers generally fall under food labeling rules instead, which is a different checklist. I cover it in how to design a cocktail syrup label.

Can I change the label after it's approved?

Some changes are allowed without applying again, and some aren't. TTB keeps a list of allowable revisions. Check it before you reprint.

Jason Guillard is a brand identity and packaging designer in Miami, working with beverage brands and independent businesses. Alongside his design work, he's spent years making cocktails, syrups, and cordials behind the scenes in Miami Beach. Related: How much does beverage label design cost?

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info@jasonguillard.com