The trend towards lower alcohol wines is gaining momentum in the consumer market, offering a welcome alternative to higher alcohol content wines while preserving flavor. For individuals seeking a more health-conscious or moderate drinking option, these lower alcohol wines are proving to be a popular choice.
However, in the quest to market these wines, companies often face challenges when labeling them as alcohol-free. This phrase raises several questions: Who regulates alcohol-free wines? What exactly does the term entail? Is it appropriate to label a wine as “alcohol-free” when it contains a minimal alcohol content?
The Regulation of Alcohol-Free Wine
Wines with an alcohol content under 7% alcohol by volume fall within the labeling of the Food and Drug Administration (FDA) for labeling purposes. This includes alcohol-removed or dealcoholized wines, as well as those labeled as alcohol-free. For detailed insights into wines with under 7% alcohol by volume, please refer to our post Everything You Need to Know About Wine Under 7% Alcohol By Volume and the FDA.
How is “Alcohol-Free” Wine Defined?
According to the FDA Compliance Policy Guide 510.400, the claim “alcohol-free” signifies that the product contains no detectable alcohol. Thus, any wine labeled as “alcohol-free” should indeed be void of any detectable alcohol.
Is it misleading to label a wine as “alcohol-free” when it contains detectable alcohol? Per the FDA’s policy guide, it is indeed misleading to use the term “alcohol-free” on the label of a wine with detectable alcohol content. Therefore, wine producers must ensure their product is truly devoid of any detectable alcohol before asserting it as “alcohol-free.” To the extent the wine does contain detectable alcohol and is labeled as “alcohol-free,” it could be in violation of the FDA food labeling regulations and potentially rendered misbranded.
How can Lindsey Zahn P.C. help you with a wine that is under 7% alcohol by volume?
Lindsey Zahn P.C. guides wine companies through the maze of federal and state regulations, assisting with permit and license applications, and navigating FDA labeling requirements. Many wineries find themselves grappling with unfamiliar FDA regulations when labeling wines under 7% alcohol by volume. The firm’s knowledge of and familiarity with both the Alcohol and Tobacco Tax and Trade Bureau (“TTB“) and FDA regulations can alleviate this challenge, providing a clear path forward.
As the demand for lower alcohol wines continues to grow, it is imperative for wine producers to navigate labeling regulations accurately. By adhering to FDA guidelines and seeking professional assistance where needed, wineries can confidently market their products while ensuring transparency and consumer trust.
Contact Lindsey Zahn P.C. to schedule an introductory meeting to discuss your needs and products and to learn more about how we can help: info@zahnlawpc.com or (929) ZAHNLAW (929-924-6529).