If you're a winemaker adding botanical extracts to a Sonoma rosé, blending a lightly sparkling Finger Lakes spritzer, or crafting a fruit-forward wine cocktail out of your Napa bonded winery, you've likely run into a labeling question that stops many producers cold: what do I call this thing on the label? TTB's featured story "Table Wine or Grape Wine with Natural Flavors?" — currently promoted on the TTB homepage — is a timely reminder that wines falling outside a recognized standard of identity carry specific labeling obligations. Getting this right before you submit your Certificate of Label Approval (COLA) is far less painful than receiving a rejection after you've already printed your first run.

Why the Standard of Identity Matters

TTB's regulations at 27 CFR Part 4, Subpart C define recognized standards of identity for wine categories such as grape wine, fruit wine, and aperitif wine [1]. When a product meets one of those definitions, the class and type designation on the brand label flows naturally from that standard. The challenge arises when your product does not fit neatly into any defined standard — for example, because you've added a natural citrus flavor, a botanical infusion, or another non-grape flavoring ingredient that takes the product outside the boundaries of a standard category.

A product that doesn't meet any standard of identity cannot simply be called "wine" or "Chardonnay" on its brand label without more. TTB requires a truthful and adequate description so consumers understand what they're actually buying.

The Statement of Composition Requirement Under 27 CFR 4.34

Under 27 CFR 4.34, wines that do not meet a standard of identity must bear a truthful and adequate statement of composition on the brand label [1]. This is the regulatory hook that governs the entire category of flavored wines, wine spritzers, and other non-standard wine products.

The good news: the statement of composition does not have to list every single ingredient [1].

Choosing between "Table Wine" and "Grape Wine" depends on the actual composition of your base. If your product is made entirely from grapes, "Grape Wine with Natural Flavors" is typically the more precise and appropriate designation. If the base includes other fruit components or if the grape character is less dominant, "Table Wine with Natural Flavors" may be the better fit. When in doubt, aligning the designation as closely as possible with the actual composition reduces the risk of a COLA objection.

How the Designation Affects Your COLA Submission

When you open a COLA application in COLAs Online for a flavored wine outside a standard of identity, the designation field is one of the first points TTB specialists review. Here's what to keep in mind:

Formula approval comes first. For wines with added flavors, TTB typically requires a formula approval through Formulas Online before or alongside the COLA. The formula on file must match what's declared on the label. A mismatch between your approved formula (e.g., "grape wine base + natural citrus flavor") and your label statement is a leading cause of COLA rejections.
The statement of composition must appear on the brand label. TTB's position is that the statement belongs on the brand label itself, not tucked on the back panel or in fine print. Placement matters during review.
Class and type field in COLAs Online. When filling out your COLA application, the class/type you enter should reflect your chosen statement of composition — "Table Wine with Natural Flavors" or "Grape Wine with Natural Flavors" — rather than a standard designation like "White Wine" or "Rosé Wine." Entering a standard designation for a non-standard product is a common source of objections.
Alcohol content and tax class. Your statement of composition doesn't change the underlying tax classification, which is still determined by alcohol by volume. Make sure your alcohol content statement is accurate and consistent with what your Willamette Valley or other producing region bonded winery reported on its formula.

Common COLA Rejection Traps

Producers submitting COLAs for flavored wines tend to encounter the same handful of rejection reasons. Being aware of them in advance can save you weeks of back-and-forth:

Using a standard designation when the product doesn't qualify. Calling a botanically infused grape wine simply "White Wine" or "Sauvignon Blanc" when added flavors disqualify it from that standard is one of the most common — and most avoidable — errors.
Formula and label mismatch. If your approved formula describes a specific natural flavor and your label uses a different or broader term, TTB will flag it. Keep formula language and label language in sync.
Omitting the statement of composition from the brand label. Moving the statement entirely to the back label, or embedding it in an ingredient list without making it a prominent designation, often draws an objection.
Vague or inaccurate composition wording. Statements like "Wine with Flavors" or "Flavored Wine" without specifying natural vs. artificial may not satisfy the "truthful and adequate" standard. Be specific: if you're using natural flavors, say so.
Health warning statement placement. Non-standard wines still require the Surgeon General's health warning statement on every label. Forgetting it, or placing it in a font size that doesn't meet requirements, is a separate but frequently cited deficiency.

Practical Steps Before You Submit

Before you open your next COLA application for a flavored wine, run through this quick checklist:

Confirm your formula is approved in Formulas Online and that the flavor description matches what you intend to declare on the label.
Choose your designation — "Table Wine with Natural Flavors" or "Grape Wine with Natural Flavors" — based on your actual base composition, and place it prominently on the brand label.
Verify the class/type field in your COLA application matches your designation exactly.
Check alcohol content accuracy against your production records and bonded winery reports.
Review placement of mandatory information: health warning, net contents, and the statement of composition itself.
Search the Public COLA Registry at TTB.gov to see how similar products have been approved — it's a free look at real-world precedents.

TTB is actively drawing industry attention to this labeling obligation through its featured guidance on the topic. If you have flavored wines in your portfolio — from a lightly botanical Napa pét-nat to a fruit-and-wine spritzer out of Finger Lakes — now is the right moment to audit your existing COLAs and make sure your designations hold up.

Managing label compliance alongside cellar records, lot traceability, and formula documentation is exactly the kind of workflow where purpose-built winery software pays off. Cepaos tracks your production lots from vineyard to bottle, maintains the additions and blending records your formula approval depends on, and supports TTB regulatory compliance reporting — so when it's time to submit a COLA, your records are already in order.

Learn how Cepaos supports TTB compliance for your bonded winery →

Sources

Table Wine or Grape Wine with Natural Flavors? | TTB: Alcohol and Tobacco Tax and Trade Bureau — ttb.gov, accessed October 28, 2026. https://www.ttb.gov/node/904066