What are the rules for transfer of unlabelled bottled wine?

 

When unlabeled bottled wine is transferred among two or more bonded wine premises for aging or labeling, the bottler must provide a copy of the approved Application For And Certification/Exemption of Label/Bottle Approval (COLA) TTB Form 5100.31 under which the wine was bottled. The transfer in bond record which accompanies the wine must be accurate and specific, and the label information record for the wine must fully support any claims made on the label to be affixed to the wine.

The responsibility for transferring accurate label information is not that of the producer alone; it is the responsibility of all holders of the wine from the time it is produced until it is removed from bond for consumption or sale.

Here are guidelines for the various parties that may be involved when unlabeled bottled wine is transferred among bonded premises:

What are the responsibilities of the Producer?

The producer of the wine must ensure that the transfer in bond record required by 27 CFR 24.309 contains accurate and specific label information for all bulk wine shipped in bond (or tax paid) to another premises for bottling. This allows the bottler to apply for a COLA and ensures that the product label is correct.

What are the responsibilities of the Bottler?

The bottler obtains a COLA which can be substantiated by the transfer record which accompanied the wine from the producer. Unless the wine will be bottled at a tax paid wine bottling house, the bottler will make sure that the wine to be bottled is received and maintained on bonded (not tax paid) premises. The bottler maintains records in accordance with 27 CFR 24.308.

If the bottler transfers unlabeled bottled wine to another bonded premises for labeling, the bottler must send the wine in bond (untaxpaid) with the COLA under which the wine was bottled. If a different product label will be affixed, the bottler must obtain a correct COLA, and forward it to the premises where the label will be affixed. The transfer in bond record that accompanies the bottled wine must contain accurate and specific information which substantiates the product label, as specified by 27 CFR 24.309. However, if unlabeled bottled wine is transferred to another bonded premises for aging only, and will be subsequently returned to the bottler for the affixing of the product label, the COLA does not have to accompany the shipments.

To reiterate, an approved label which accompanies the wine must carry the minimum label requirements, but it might not be the label eventually affixed to the product. The label used to bottle the wine is sometimes referred to as the “generic” label. The bottler may apply for another COLA for a product label with specific label claims, as long as the claims are substantiated by the label information record requirements of 27 CFR 24.314.

What does the Labeller receive from the Bottler?

The person who will affix the product label receives the unlabeled, untaxpaid bottled wine, the COLA for the product label to be affixed, and the transfer in bond record (27 CFR 24.309) which contains accurate and specific information which substantiates the label claims.

Only the bottler of the wine may apply for a COLA. If the owner of unlabeled bottled wine wants to label the wine with a label other than that which accompanied the wine, the bottler must be contacted, and the bottler must work with the owner to obtain an approved product label which is fully substantiated by the label information record for that wine.

What if the bottler is unable to provide a COLA?

If the bottler of the wine is unable to obtain label approval for the wine to be labelled, the wine may only be labeled if it is dumped to bulk and re-bottled. It may be re-bottled when an appropriate COLA is obtained by the bottler. The label may not contain any information which is not fully supported by the label information record for the wine.

Red wine in glass bottling machine at winery

What is the responsibility of the person who removes the wine from bond?

If the labelled wine is transferred in bond to another bonded wine premises for taxable removal, it must be accompanied by the transfer in bond record (27 CFR 24.309) which contains accurate and specific information which substantiates the label claims.

The person who pays the tax on the wine is the qualified proprietor of a bonded winery or bonded wine cellar, and not a wholesaler, wine broker, agent, negotiate, retailer, consumer or, necessarily, the actual owner of the wine. Bottled wine may not be removed from bond (i.e., tax paid) without a COLA and an approved product label being affixed. This requirement is given in the wine regulations at 27 CFR 24.257(a) which states in part: “The proprietor must label each bottle or other container of beverage wine prior to removal for consumption or sale.”

How long the records must be kept?

All records must be retained for a period of not less than three years from the record date or the date of last entry required to be made in the record, whichever is later.

However, TTB may require records to be kept for a period of not more than three additional years, if deemed necessary.

Source: https://www.ttb.gov/wine/wine-faq.shtml

Only 20 Spots are left to become an Exhibitor at the 2017 International Bulk Wine and Spirits Show. Register Now and Join the show as an Exhibitor.

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Bulk Wine, Bulk Spirits and Private Label Show Comes To Europe in 2018

International Bulk Wine and Spirits Show (IBWSS) which is an annual show in San Francisco that caters to the US bulk wine, bulk spirits and private label buyers now also comes to London. IBWSS London will be an annual event exhibiting global bulk wine, bulk spirits and private label service providers. The IBWSS London will give European supermarkets, retailers, restaurants, wineries, distilleries and other buyers an opportunity to source bulk wine and spirits in one place, and meet private label suppliers.

Event Date: Jan 24-25, 2018

Location: The Royal Horticultural Halls Lindley Hall, London

Bulk Wine - IBWSShow London - 2018

“The bulk segment holds the largest market share in the wine and spirits industry,” said Sid Patel, CEO of Beverage Trade Network.  “Bulk trading is an age-old trade between producers, but we are now seeing the business take on a very impressive position across the industry. The International Bulk Wine and Spirits Show aims to give the bulk trade a truly dynamic trading platform where buyers can confidently conduct business with the world’s most reputable suppliers.”

As the central exchange for European trade, London is positioned perfectly for the fair. The city has long acted as the European trading post between the northern and southern hemispheres.  With the launch of IBWSS, international bulk suppliers from some of the world’s most important markets will have unprecedented access to the European market.

Registration for The International Bulk Wine and Spirits Show will open to all international suppliers on March 1, 2017. IBWSS London is brought to you by Beverage Trade Network.

For more information, press releases and launch discount for exhibitors, please fill out interest form here: https://goo.gl/forms/zrHJ8461hV0ZFRi32

About Beverage Trade Network

Beverage Trade Network (BTN) is a leading online marketing and B2B networking platform servicing suppliers, buyers and beverage professionals in the global beverage industry. BTN provides a selection of sourcing solutions for importers and distributors as well as an extensive range of marketing and distribution services for international suppliers. BTN also runs a line-up of b2b trade shows around the world. For more information about BTN, please visit www.beveragetradenetwork.com

About The International Bulk Wine and Spirits Show

The International Bulk Wine and Spirits Show (IBWSS) is an annual trade show and conference, open to trade professionals only, that takes place takes place in London, UK and San Francisco, CA. IBWSS exhibitors are wineries and distilleries looking to sell bulk wine and spirits, producers and negociants who offer contract manufacturing / private label programs and wineries / distilleries / importers who have one time excess stock to clear. IBWSS buyers are other wineries and distilleries looking to meet up their demand, Importers, Retailers and Distributors looking for private label programs, negociants who are looking to meet the growers and producers.

2018 International Bulk Wine and Spirits Show – Exhibitor Registration (London) Now Open Register Today!

Key Retailers Like Marks & Spencer Drives Own Label Wine Growth

Mark & SpencerAndy Crossan, consumer insight director at Kantar Worldpanel told db that despite the challenges facing still wine from other drinks, especially sparkling wine and the booming popularity of gin, premium own labels had made strong gains in the latest 12 week-period as consumers trade up from cheaper branded lines and private label tiers.

“Premiumisation is a major theme in alcohol right now,” Crossan told db.”Still wine continues to face challenges from competing sectors like sparkling wine and gin, which have made significant gains from shoppers switching out of the sector.  However, there are promising signs as premium own label still wines gain more traction with shoppers in this vital period running up to Christmas.”

He highlighted that in the 12 weeks to 4 December, premium own label bottles – wines over the £8 price mark – had attracted 440,000 more households than in the same period last year.

“Shoppers returning to the still wine aisles have traded up from cheaper branded and private label tiers to these more premium options some 700,000 times,” he said.

One of the key drivers of this was UK retailer Mark & Spencer, he noted, which had seen a resurgence at this price point  “Just under half of still wine volume for the retailer has come from bottles over £8 in the last 12 weeks – up from 30% this time last year and taking shopper numbers within this tier to an all-time high of 1.1 million households,” he said.

“Of the big four, Tesco and Morrisons have seen penetration increase in premium private label, as has Aldi, which continues to expand its premium offering and appeal to an even wider range of shoppers.

Earlier this week the market analysts predicted strong growth of top tier own label lines across the board for Christmas.

M&S recently bolstered its range fine wines ahead of Christmas, after reporting “phenomenal” sales growth of over 40% sales growth in its fine wine range, and is set to boost the number of Simply Food outlets by 200 in a major two-year overhaul of its store estate.

In September, Tesco added more than 20 new lines to its own label range, which it said saw “significant” growth over the summer. The retailer has invested in its premium own-label range this year, with a successful Soho pop-up to promote its finest* range.

Only 20 Spots are left to become an Exhibitor at the 2017 International Bulk Wine and Spirits Show. Register Now and Join the show as an Exhibitor.

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