Except you should be able to use “rhone-like” if you want, it’s a perfectly good descriptor.
Most labels, AFAIK, are just repeats of previous year’s. Is it actually not legal to go ahead and bottle with an unapproved label, or is the problem that you don’t want to risk doing that, and having them come back with a problem after the fact?
Alan,
So a producer should be able to use ‘just like Burgundy’ on their back label? Or use ‘Champagne’ or perhaps say ‘the most highly rated wine ever’ or ‘wine crap 100 point wine’? Rules and regulations are set up perhaps more stringent than they should be, but they prevent crap like that . . .
And yep, folks are worried that if their labels are not approved, there’s always a chance that they’ll bottle with ‘faulty’ labels and have to do something after the fact
Cheers
There’s no law against bottling with an unapproved label. Think of the label as just a sticker at that point. Until it’s approved, you can’t sell it.
If that label gets approved, then you’re good to go and start selling. If it comes back with corrections needed, you just bottled a whole bunch of wine with a useless sticker on it that you can’t sell.
As long as the information on the front is correct (vintage, vineyard, AVA, etc.) I don’t really care what description you put on the back label 
I’d much rather have government clamping down on the supplement industry and their ridiculous claims than worrying about your label. The way it should work, if we really need label police, is to set out guidelines, leave producers to work within those guidelines, and if a producers strays way out of line, deal with them after the fact.
Actually, pretty much all food products have some sort of label oversight. Unless you are against truth in labeling and in favor of fraud, I don’t see why you’d have an issue with it. While the shut-down is an inconvenience for those of us in the business, it’s a disaster for many more who work as Federal employees.
Rick, of course, truth in labeling is important, I’m not arguing that. I’m arguing the value of having a TTB control every aspect of wine labels.
Do food companies have to get their labels approved before they can sell something? I don’t actually know the answer to that.
The FDA doesn’t pre-approve labels, but they can fine you and recall your product if your label isn’t within the law. They have a 130+ page guide on what a food producer can or can’t do. The actual regulations are significantly longer. Most food producers will work with a label designer that knows all the legal stuff to keep within the rules. The cost and time it takes to create a label is much higher/longer than producing a wine/beer label. Wine/beer producers have a fraction of the regulations to follow. Frankly, label approval usually isn’t a big deal. As someone pointed out above, it was taking three days prior to the shut-down.
Many small updates to labels do not need to be re-submitted for approval, such as vintage year updates or alcohol % changes.
Complete list of allowable revisions here: https://www.ttb.gov/labeling/allowable_revisions.shtml
Carole
Exactly. Thanks for the concise answer, Carole.
Thanks for the facts Carole.
Not that it will stop the debate, but thanks. 
Hey, I was only trying to understand the process in light of posts like this:
Glad to hear it’s not affecting those with minor label changes. That’s not much consolation for those with new products or labels in the pipeline who are being affected.
BTW, we’ve been trying to avoid having our labels regulated by the FDA for at least a decade.
Know of somene waiting on a duplicate 02 approval to open their new tasting room. Paying rent and not being able to open the doors is not a great way to start.
Alan,
“Truth in labeling” is an interesting concept, and will result in a rather lengthy discussion, with at least the OP deep in it, going back to a very old Parker thread on same subject. For all the hand wringing here and elsewhere “truth” is not really enforced, as a good number of Old World labels omit it. And TTB has no real means of testing each and every wine, and I am the last person wanting expansion of TTB. But speaking of “truth in labeling” and alcohol levels, specifically, that clock in at well into 15+ levels, but labeled way, way less. Been going on for decades, really, main reason every time I see a discussion of “New World wines suck due to high alc and Old World are so much better with low alc” pop up again and again it is just a laugher, so many are caught in the discussion while having little or no info on hand. Many here (USA) have equipment on premises they use to analyze Old World wines, some send it out to a lab, out of curiosity as well as learning process, French wines in particular. Listen to that Ramey interview, link in premox thread, and he’s not alone, by far, I knew of this at least a dozen years ago. I know that you personally know some winemakers who do similar lab testing since we sometimes discuss it offline. Placibo effect is in play as well, with so many caught up in the “low alc” French wine phenomena only because a label says so. TTB never actually tests for anything in regard to what’s REALLY in the bottle, otherwise you’d see some seriously hefty fines handed out for openly lying on labels going back a while, lying on labels allowed wineries to save a lot on per gallon taxes paid, at least with an under/over 14% threshold. A big no-no. And a double whammy when a wine at 15.6%, for example, is labeled as 13.9%, breaking 2 laws, actually. Both here and in EU, BTW. So much for “truth in reporting”. TTB was, and still is, clueless.
Not sure what “truth in labeling” really is, or means. Not tested, not enforced. Only relying on what importer/winery claim. Watch that Ramey interview, its a classic, in so many ways, and consumers, in particular, really need to pay attention and understand him pointing out things, he’s one of few who seems to be not afraid to state the obvious. Then go back to that Adam Lee and Rajat Parr “low alc” placibo effect so well played by Adam, that was, and should be, required watch/read for all the “low alc” aficionados. So, indeed, what is “truth in labeling”? And, moreover, just how does it “protect” consumers when there is no harm, no foul, so to speak?
For example. I, for one, want use of RO to be disclosed, since its a highly manipulative process, when some in Bordeaux (originators, LLC anyone?) and Napa use it for good many years now, and I question some in Sonoma as well seeing labels that do not “correlate” to tasting notes and numbers provided (but maybe I do not understand the red fruit/blue fruit spectrum divide). That said, I am fine with things as they are now, when consumers are happily drinking high alc wines and perceive them as low alc, great! Heck, even Rajat was happy. Everyone wins, right?
If these wineries are now forced to disclose actual alc levels, for example, will consumers buy them less, stop buying them outright, or won’t care? What’s that movie line, Truth is what I say it is. Exactly how label approval has been going on for eons.
Wine world is not the rosy unicorn breeding and populated dream land so many think it is.
But back to the thread subject.
In regard to “suffering”, and I am also affected since we moved to new facility last year and now need COLA approval, I suspect MOST, by far, are not really affected. Unless its a new label altogether, per OP and others above, or a new vineyard source for established winery, pretty much most, if not all, prior vintage(s’) labels are good to go; you simply update vintage and print/bottle, you don’t even submit for COLA. I am sure we will all get approvals prior to bottling, no panic at this point.
Am I a fan of TTB? Absolutely not. Seen good labels rejected for font size being off by a frigging 1pt?!, while labels such as Bitch and Stu Pedaso and some others like them, are approved (but children!, children!). Fair? Not to me. But that’s life, and not just in wine world.
ou will be able to access TTB’s eGovernment applications, including Permits Online, Formulas Online, and COLAs Online, during the shutdown period, but submissions will not be reviewed or approved until appropriations are enacted. TTB will suspend all non-excepted TTB operations, and no personnel will be available to respond to any inquiries, including emails, telephone calls, facsimiles, or other communications. The website and operations will fully resume when appropriations are reenacted. TTB has directed employees NOT to report to work and they are prohibited by federal law from volunteering their services during a lapse in appropriations. This is what’s happening to importers.
Aha. I didn’t realize that an 02 license (even for a second location tasting room) required Federal TTB approval. We may be talking about the same winery.
Thread drift on my own thread:
Greg P is whining about all of the vicious French criminals who label their 15.6% wines as 13.9% and have broken TWO! laws.
Who cares? The vacuity of this comment is impressive. The % of consumers who look at the alcohol content on a wine label is probably waaay under 1%.
And I am happy to report that (if what my office tells me is accurate) the law has been changed so that the legal limit for table wine has been raised from 14% to 16%. Maybe some of my viciously, savagely criminal Mediterranean producers who label wines with 14.9% alcohol as 13.9% will reform, at no cost to the millions of consumers who have been deluded by these evil French winegrowers into thinking that they were drinking low alcohol Mediterranean Grenache.
not quite commercial post:
The average alcohol content of the wines from my vineyard has been 15% over the 12 years of production. All of the wines have been labeled 15%, except for a few from really miserable, nasty, underripe vintages, which have been labeld 14.5%. As a producer who Greg P probably would blatantly dishonest, I have never bothered to label to within 0.1%, as you can test the same wine on the same equipment over a period of a month or two and get slight variations.
Dan Kravitz
What precipitated this rant? I think the number of fine wine lovers looking at alcohol levels is more than 1%! Ideally, producers should properly label each vintage and post it somewhere, either on the label, website, sticker…whatever. It’s called truth in advertising.
Dan,
You openly lied before and you are lying again. 15.6% is not 14.9%, and definitely not 13.9% as you and your client have labeled the wine. The only issue is that in pretty much all cases its assumed that only the CA wines seem to “obfuscate” the numbers, while many producers do with consumers non the wiser. As you know by now, you were not reported by any of us, last thing you should do is dance in triumph at this point, since your utter (and obvious) disregard of laws may actually trigger someone to report you, eventually. Have no idea why you think that your past indiscretions are somehow past limitations of the law.
My point was that nothing seems to be an issue with French wine consumers who, in reality, have proven that placebo effect is at play while they all complain about too much alc in CA wine. Seems as long as one disregards truth in labeling all is fine and, for some strange reason, same consumers demand CA only wines to be truthful in labeling assuming that all others are already. Fallacy, in many ways.
You, of all people, should not be complaining about shutdown and issues since you so blatantly disregarded them before.