As a firm that has worked with various packaging form factors one criteria remains constant for all them: labeling compliance with the Treasury Department’s Alcohol and Tobacco Tax and Trade Bureau (TTB). For traditional glass bottle packaging, it’s pretty straightforward with both the requirements necessary on wine labels, as well as the process for submitting for a Certificate of Label Approval (COLA).
For alternative wine packaging, it really isn’t that much different. The requirements are pretty much the same, mandating the same components of government and sulfite warnings, packing statement, container size, and wine information in easily readable layout. The only difference is – sometimes – how you provide the packaging design for a COLA. For form factors such as a bag-in-box or pouch, the entire package’s surface must be submitted for approval, since the entire surface is utilized as a label.
In an article on the website Wine Compliance Alliance (winecompliancealliance.com), the author discusses the process involving 5-gallon kegs destined for on-premise by-the-glass programs. In this instance, creating a label for the container results in the same process as one would do for glass bottles.
The only factor to keep in mind is container size; the TTB has specifically approved container sizes, and all sizes must be noted in metric volumes (milliliters, liters):
“The first change was of course for the capacity of the larger container. You actually can’t list ‘5 Gallons’ on a wine label. In this case, the TTB only accepts capacity amounts in whole liter statements. For the required net contents on a 5 gallon keg label it would need to state ’19L.’“
Read the full article on Wine Compliance Alliance: