In April, the Alcohol and Tobacco Tax and Trade Bureau (“TTB“) clarified its position with respect to the use of the term “clean” on wine labels and advertisements. To date, there are no formal rules or regulations that discuss “clean” and TTB’s clarification is not a legal ruling nor has it defined the term. The agency indicated that consumers should not read the phrase “clean” to mean that the wine is organic or that it has met production standards set by TTB.
TTB also reminded industry members that the agency reviews labels and advertisements in totality. For that reason, the use of the word “clean” could mean several different things depending on the context (e.g., “a clean and crisp wine” could be a description of the wine’s taste and may be considered puffery by TTB). In other instances, the term may be used to indicate that the wine has some degree of health benefits, which is generally prohibited under 27 CFR Part 4 regulations and likely would be considered misleading by TTB.