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TTB adopts changes to wine labels allowing a vintage date on labels reflecting a country as an appellation of origin.

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Blog 11, 38, and 39

Effective November 13, 2012, TTB adopted a new rule that allows a vintage date to appear on wine that is labeled with a country as an appellation of origin. It is anticipated that both domestic and foreign winemakers will benefit from more flexibility for grape sourcing and wine labeling.

Prior to the adoption of this rule, regulations defined “vintage wine” as wine labeled with the year of harvest of the grapes and the wine must be labeled with an appellation of origin other than a country, which would not be allowed on such a label. The historical rationale of such a rule seems to date back to the late 1970s. TTB implied in their explanation that in order to protect consumers, the vintage date should provide consumers information about harvest conditions and presumably using a country as an appellation of origin would simply be too broad, thereby potentially misleading consumers.

So why the change now? The European Commission petitioned TTB for the change because they felt the rule created difficulty for its member countries. The Commission argued that it was unfair to allow an appellation of origin for a state like California, when a member of the Commission like Portugal was geographically smaller, but could not be an appellation of origin on a vintage wine.

Further, they argued that the rule was inconsistent. As an example, the general varietal labeling rule states that one or more grape varieties may be used as the type of designation of a grape wine only if the wine is also labeled with an appellation of origin. For this purpose, the regulations included countries within the definition of “appellation of origin.”

Ultimately, the arguments were persuasive. Some industry members expressed concern, but TTB indicated the majority of commentators were positive and the vintage date can provide useful, truthful information to consumers. TTB believes that an adjustment to this regulation will better allow it to meet its regulatory requirements of under the Federal Alcohol Administration Act to prohibit consumer deception and the use of misleading statements on labels, while ensuring that labels provide the consumer with adequate information as to the identity and quality of the product.

Should you have any questions about this or any other label issue, please contact our office.

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Dear friends in the alcoholic beverage industry,

As we as an industry, nation and planet collectively try to navigate this unprecedented period the coronavirus has brought us, We’d like you to know that we at Craft Beverage Consultants (the other CBC!) are here to answer any question you may have (or not know you have) about not just surviving this time but positioning yourself to thrive as soon as social distancing measures allow your business to function at full capacity again.

If you schedule a free 60-minute phone or video conferencing consultation with me or any of my 11 highly specialized colleagues, we’ll help you figure out any of your immediate and/or longterm business needs, or “everything but the staffing,” as we like to say. We’re not high-pressure sales kind of people, especially these days, so you don’t have to worry about fending off annoying pitches. Make an appointment on our website or Facebook page, or just call us the old-fashioned way at 314-768-0220.

Our experts have a combined 150 years in the alcoholic beverage industry, with deep knowledge in everything from sales and distribution, production, and regulatory compliance to marketing, package design, event planning, IT, (social) media, hospitality, and even values-based executive coaching. 

For example, we can coach you through this season when chain accounts have canceled their spring, in some cases, fall resets and distributors have drastically cut orders. Our director of business strategy and compliance can save you money – now – on excise taxes, caution you to avoid naming your beers in ways that risk alienating your buyers (Wuhan Wheat? Coronavirus Cream Ale? Groan. No.), and secure TTB approval for the tastefully named beers you do make. Our creative director and web team can get your e-commerce site up and running and launch a social media campaign that keeps you top of mind for current and future customers. Our director of storytelling can put you in front of the press so you can tell your story to your community. 

Once you’re ready, we can look forward together. Now is the time to talk about post-virus. We all suspect the legal landscape to look different. But how? And how do you prepare yourself in a way that positions you to charge out of the gate ready to maximize the potential and profit of whatever the “new normal” turns out to be? Please get in touch so we can talk about it. 

CBC’s roster includes local and regional clients like Epic Brewing, Logboat Brewing, Piney River Brewing, SudWerk Brewing, Waves Cider and Common Cider Company, just to name a few.  The agency was founded in 2004 by Jacob and Beth Halls, formerly known as Convergence Consulting; Rick Laxague, joined as a partner in charge of sales, marketing and distribution consulting in 2019. 

Rick hase close to 20 years of experience, a bulk of which was with Crescent Crown Distributing in Arizona. His last role there was Area Sales Manager for the dedicated craft beer division, coaching and leading a sales team to be nationally recognized. In early 2014 Rick helped take a regional brewery national as their Director of National Accounts and increase that segment of their business from 30,000 cases to almost 300,000 cases in two years, an increase that equates to $4.8 million in IRI dollar sales. 

Co-founder Jacob Halls brings 17 years of experience in regulatory compliance, business strategy, marketing and craft brand management to the company. In his former position as craft brand manager for the N.H. Scheppers Distributing Company in Columbia, Missouri, Jacob helped lead his team to winning the 2016 Distributor of the Year award from New Belgium and to a nomination for the Brewers Association’s Distributor of the Year award. Jacob is also the founder and director of the South East Craft Beer Fest and several other industry specific charitable event marketing festivities. Beth Halls is Director of Business Operations and Coordinator of Charity Operations for the festivals and events run by CBC, such as the South East Craft Beer Fest, MO Bacon & Bourbon, and many more. 

Again, please reach out to us for anything.  CBC can be reached at (314) 768-0220 or at craftbeverageconsultants.com.

We look forward to meeting/talking soon.

Sincerely,

Rick Laxague, Jacob Halls, and Beth Halls