Rev. Ruling 64-325

Vin Rose Wine

Section 4.34(b) of the Federal Labeling and Advertising of Wine Regulations under the Federal Alcohol Administration Act requires that an appellation of origin such as "American," "California," "Chilean," "New York State," or "Spanish," disclosing the true place of origin of wine, shall appear in conjunction with the class and type designation of the wine (1) if the wine's designation includes a grape varietal name of geographic significance; or (2) if the wine's designations is a semigeneric type designation of geographic significance; or (3) if the label bears any statement, design, or representation which infers origin other than the true place of origin.

"Vin Rose" has been used so extensively as a class designation of wine produced in the United States, and ofwine imported from countries other than France, that the name has lost significance to the consumer as anindicator of origin.

Held, if the label clearly and conspicuously states that "Vin Rose" wine is a "product of (country to be inserted)" or that is "Made and Bottled X Wine co., City Y, State or Country Z," the consumer is considered adequately informed as to the origin of the wine and no appellation of origin, as required by section 4.34(b) of the regulations, is necessary unless the label otherwise creates an erroneous impression of origin.

27 U.S.C. 205; 27 CFR 4.34