
The Alcohol Tax and Trade Bureau (TTB) recently made an announcement reminding everyone that shiners do not need to be labeled before removal to other bonded premises for purposes of aging and labeling.
“Shiners” are finished bottles of wine without labels. It may seem strange to some, but unlabeled wines are quite common. Often, a producer or winery wants to sell the unlabeled wine for wholesale/retail use. Sometimes, it is more practical for the wholesaler or retailer to affix a custom label to the bottle, in which cases the bottler is not required to follow the typical label requirements before being moved.
Although TTB regulations state that shiners are allowed to be moved between bonded premises only for the purpose of aging, TTB has made clear that shiners are also allowed to be moved between bonded premises without a label for the purpose of labeling. However, a label must always be affixed to the bottles of wine before they are moved from the bonded premises for purposes of consumption or sale.
Prior to bottling the wine, the bottler must obtain a Certificate of Labeling Approval (COLA). When the unlabeled wine is being transferred, the COLA has to be present with the shipments. The only time the COLA does not need to be present with the shipments is if the unlabeled wine is being transferred to another bonded premises for aging purposes and will subsequently return to the bottler for labeling. The other requirement for unlabeled wines is that the bins, cases, or containers must be generally labeled with the wine's class, type, and alcohol content.
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