PROCEDURE FOR OBTAINING LABEL APPROVALS FOR
IMPORTED LIQUEURS, CORDIALS, FLAVORED SPIRITS
AND DISTILLED GINS
Importers and others concerned
Purpose. This circular announces the future publication of an
ATF Procedure which will be published in the next Alcohol,
Tobacco and Firearms Quarterly Bulletin. The procedure will
read substantially as follows:
Section 1. PURPOSE
This procedure provides guidelines for obtaining Federal label
approval for imported liqueurs, cordials, flavored spirits and
distilled gins.
Section 2. BACKGROUND
Liqueurs, Cordials and Flavored Spirits
The Bureau has consistently held that importers of all imported
liqueurs, cordials and flavored spirits must obtain a statement
from the foreign producer listing all ingredients and must
submit a minimum 750 ml sample for analysis prior to issuing
certificates of label approval.
Section 5.33(g) of Title 27, Code of Federal Regulations reads
as follows:
(g) Contents of bottles. A complete and accurate
statement of the contents of the bottles to which labels
are to be or have been affixed shall be submitted, on
request, to the Director or the regional director
(compliance).
Distilled Gins
Section 5.22(c), Class 3, defines "gin" as a product obtained
by original and continuous distillation from mash, or by
redistillation of distilled spirits, or by mixing neutral
spirits, with or over juniper berries and other aromatics, or
with or over extracts derived from infusions, percolations, or
maceration of such materials, and includes mixtures of gin and
neutral spirits. It shall derive its main characteristic
flavor from juniper berries and be bottled at not less than 80
proof. Gin produced exclusively by the original distillation
or by redistillation may be further designated as "distilled".
In order to properly determine the class of an imported gin,
the Bureau has always required that a statement of process be
submitted prior to issuing label approvals for gins designated
as "distilled" in accordance with 27 CFR 5.51(d). Section
5.51(d) reads as follows:
(d) Statements of Process. Forms 1649 covering labels
for gin bearing the word "distilled" as a part of the
designation shall be accompanied by a statement prepared
by the manufacturer, setting forth a step-by-step
description of the manufacturing process.
The Bureau has determined that several reasonable alternatives
exist as to obtaining certificates of label approval for
imported liqueurs, cordials and gins.
Section 3. ACCEPTABLE PROCEDURES
Prior to issuing certificates of label approval, the Bureau
will require one of the following pieces of documentation:
Liqueurs, Cordials and Flavored Spirits
1. A statement of ingredients from the manufacturer and a
750 ml sample; or
2. A statement from the manufacturer that the product to be
imported is identically formulated for world-wide distribution,
provided ATF has a list of the ingredients on record, and a
750 ml sample; or
3. A 750 ml sample, and a statement from the importer
setting forth the specific contents of the product. Such
statement must be supported by a laboratory analysis performed
by a commercial laboratory as to the specific ingredients
contained in the product, and should differentiate between
natural and artificial ingredients, colors, flavors, etc.
Distilled Gins
1. A statement of process from the manufacturer specifying
the step-by-step process by which the "Distilled Gin" is
manufactured; or
2. A statement from the manufacturer that the product to be
imported is identically formulated for world-wide distribution,
provided ATF has a statement of process on record.
Section 4. LIMITATIONS
The Bureau reserves the right to require resubmission of the
appropriate documentation and/or samples in situations where
the Bureau has reason to believe the product has been changed,
or when required by the Director.
Section 5. INQUIRIES
Inquiries concerning this circular should refer to its number
and be addressed to the Associate Director (Compliance
Operations), Bureau of Alcohol, Tobacco and Firearms, 1200
Pennsylvania Avenue, N.W., Washington, DC 20226.
![Stephen Higgins](https://webarchive.library.unt.edu/eot2008/20090117194515im_/http://ttb.gov/images/higgins_signed.jpg)
Director |