LABELING ORGANIC DISTILLED SPIRITS

All organic alcohol beverages must meet both Alcohol and Tobacco Tax and Trade Bureau (TTB) and
USDA organic regulations. TTB requires that alcohol beverage labels be reviewed through the Certificate of Label
Approval (COLA) application process. Learn more at https://www.ttbonline.gov/colasonline.

Organic-specific labeling requirements will be described in the subsequent pages.

Required Elements of a Spirits Label

Brand name Name and address statement

Class/type (vodka, gin, etc.) Health warning statement

Commodity statement Net contents

Alcohol content

For specific requirements related to each of these elements, other requirements, and information on
labeling imported products, visit www.ttb.gov.

CUCUMBER FLAVORED

Since 2009

CUCUMBER FLAVORED 2 There are many artisinal vodkas

in today’s market.
There’s only one smooth and
silky cucumber flavored organic
vodka that also supports local
organic farmers and helps
protect the environment.

ORGANIC 5 Bottled by
1 Common Good Distillery
Washington, DC
Certified organic by
ABC Certifiers, Inc.

6 GOVERNMENT WARNING: (1) ACCORDING

TO THE SURGEON GENERAL, WOMEN SHOULD
NOT DRINK ALCOHOLIC BEVERAGES DURING
PREGNANCY BECAUSE OF THE RISK OF BIRTH
DEFECTS. (2) CONSUMPTION OF ALCOHOLIC
BEVERAGES IMPAIRS YOUR ABILITY TO DRIVE
COMMON GOOD DISTILLERY A CAR OR OPERATE MACHINERY, AND MAY
DISTILLED FROM ORGANIC GRAIN 3 CAUSE HEALTH PROBLEMS.
ALCOHOL 40% BY VOLUME 7 750 ml
4

National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture February 2014
LABELING ORGANIC DISTILLED SPIRITS

Requirements for spirits making organic claims. In addition to TTB requirements, the USDA organic regulations
describe the specific production and handling requirements for the three main categories of organic labeling claims.
For each category (described on subsequent pages), these regulations dictate the spirits’ composition, as well as how
and when spirit labels­may make organic claims.

Organic oversight. The USDA accredits third-party certifiers (ACAs) to assess organic operations’ compliance with the
USDA organic regulations. The table below outlines some of the key requirements for each labeling category (learn
more at www.ams.usda.gov/nop):

“Organic” “Made with Organic ***” Other

Overseen by certifier/ACA? Yes Yes No*

USDA organic seal or foreign Yes No No

equivalent allowed?

Organic claims allowed in Yes Yes No

addition to ingredient statement?

All agricultural ingredients Yes, unless specifically No, but product must No
required to be certified organic? allowed per National List be at least 70% organic

Organic yeast required? Yes, unless not No No

commercially available

Ingredients produced using No No Yes

prohibited methods (e.g., genetic
engineering) allowed?

*For spirits not in the “organic” or “made with organic ***” labeling categories ONLY: COLA application must include
organic certificates (“crop reports”) for any specific ingredients identified as “organic” on the label.

Certifier/ACA + COLA review. To ensure compliance with both TTB and USDA organic regulations, a certified
operation’s alcohol labels must be approved through the following steps prior to sale of the organic alcohol product:
1. Certifier/ACA reviews the alcohol label(s) to assess compliance with USDA organic regulations.
2. Certifier/ACA stamps/signs label(s), verifying compliance with USDA organic regulations.
3. TTB permitee (importer or organic operation) completes the COLA application.
4. TTB permitee submits COLA application and label(s) approved by the certifier/ACA to TTB.
No longer requires a copy of the organic certificate. http://bit.ly/ttb-documentation

Trade considerations. USDA has trade partnerships with multiple countries. These partnerships allow organic products
certified in one country to be sold as organic in the other. Regardless of country of origin, traded products must meet
the labeling requirements in the destination country and any other terms of the arrangement. Therefore, a spirit
produced and sold in a foreign country typically has a separate label if it is also imported to the United States.

To learn more about specific trade partnerships, visit www.ams.usda.gov/NOPInternationalAgreements.

2
LABELING ORGANIC DISTILLED SPIRITS

Labeling Category: “Organic”

Spirits in the “organic” labeling category must be overseen by a certifier/ACA, who will verify that the spirits meets
all appropriate specifications in the USDA organic regulations. All agricultural ingredients (e.g., grains, agricultural
flavoring agents, etc.) must be certified organic except per the National List of Allowed and Prohibited Substances.
Any non-agricultural ingredients must be specifically allowed on the National List and may not exceed a combined 5
percent of the total product (excluding salt and water). Below is an example of an acceptable label for spirits meeting
all requirements in the “organic” category:

CUCUMBER FLAVORED

Since 2009

CUCUMBER FLAVORED There are many artisinal vodkas

in today’s market.
There’s only one smooth and
silky cucumber flavored organic
vodka that also supports local
organic farmers and helps
protect the environment.

ORGANIC Bottled by
Common Good Distillery
Washington, DC
Certified organic by
2 ABC Certifiers, Inc. 1

GOVERNMENT WARNING: (1) ACCORDING

TO THE SURGEON GENERAL, WOMEN SHOULD
NOT DRINK ALCOHOLIC BEVERAGES DURING
PREGNANCY BECAUSE OF THE RISK OF BIRTH
DEFECTS. (2) CONSUMPTION OF ALCOHOLIC
BEVERAGES IMPAIRS YOUR ABILITY TO DRIVE
COMMON GOOD DISTILLERY A CAR OR OPERATE MACHINERY, AND MAY
2 DISTILLED FROM ORGANIC GRAIN CAUSE HEALTH PROBLEMS.
ALCOHOL 40% BY VOLUME 750 ml

Why the label is acceptable

1. Certifier/ACA. The certifier/ACA is listed below the bottler or distributor (certified organic by ***). Before being
submitted to TTB, this certifier/ACA has reviewed the label and verified that the spirits meets all requirements
for the “organic” labeling category.

2. Organic seal. For “organic” spirits, the USDA organic seal (or foreign equivalent if authorized under an
equivalency arrangement with the United States) may be used anywhere on the label.

3
LABELING ORGANIC DISTILLED SPIRITS

Labeling Category: “Made With” Organic ***”

Spirits in the “made with” labeling category must be overseen by a certifier/ACA, who will verify that the spirits meet
all appropriate specifications in the USDA organic regulations. At least 70 percent of the ingredients must be certified
organic, but other agricultural ingredients (e.g., flavoring agents) aren’t required to be organic. Non-agricultural
ingredients must be specifically allowed on the National List. Below is an example of an acceptable label for spirits
meeting all requirements in the “made with organic ***” category:

CUCUMBER FLAVORED

Since 2009

CUCUMBER FLAVORED There are many artisinal vodkas

in today’s market.
There’s only one smooth and
silky cucumber flavored premium
vodka that also supports local
organic farmers and helps
protect the environment.
MADE WITH
ORGANIC RYE
Bottled by
Common Good Distillery
Washington, DC
ABC Certified organic by
CERTIFIERS
ABC Certifiers, Inc. 1
GOVERNMENT WARNING: (1) ACCORDING
TO THE SURGEON GENERAL, WOMEN SHOULD
NOT DRINK ALCOHOLIC BEVERAGES DURING
PREGNANCY BECAUSE OF THE RISK OF BIRTH
DEFECTS. (2) CONSUMPTION OF ALCOHOLIC
BEVERAGES IMPAIRS YOUR ABILITY TO DRIVE
COMMON GOOD DISTILLERY A CAR OR OPERATE MACHINERY, AND MAY
DISTILLED FROM ORGANIC GRAIN CAUSE HEALTH PROBLEMS.
ALCOHOL 40% BY VOLUME 750 ml

Why the label is acceptable

1. Certifier/ACA. The certifier/ACA is listed below the bottler or distributor (certified organic by ***). Before being
submitted to TTB, this certifier/ACA has reviewed the label and verified that the spirits meet all requirements
for the “made with organic ***” labeling category.

2. Organic claims. The USDA organic seal (or foreign equivalent) isn’t anywhere on the label. All words in the
statement, “made with organic rye,” are formatted the same (and no more than half the size of the largest text
on the label). The certifier/ACA’s logo may be present anywhere.

Note: Unlike the example on the previous page, the vodka itself can’t be described as “organic”; instead, it is vodka
made with organic rye. This has been edited appropriately in the product’s description above.

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LABELING ORGANIC DISTILLED SPIRITS

Labeling Category: Not “Organic” or “Made With Organic ***”

If the distilled spirit doesn’t meet the requirements of the “organic” or “made with organic ***” labeling categories,
it isn’t eligible for organic certification. The distiller/bottler must obtain copies of individual ingredients’ organic
certificates (“crop reports”) and submit them to the TTB along with the COLA application.

Examples of attributes that would disqualify spirits from certification, meaning the spirits couldn’t be in the “organic”
or “made with organic grapes” labeling category categories:
• Spirits contains less than 70 percent certified • An ingredient was produced through genetic
organic content engineering or other prohibited methods

Uncertified spirit labels must not use the USDA organic seal (or foreign equivalent) anywhere on the label. The
ingredient statement can identify any certified organic ingredients as organic; if the ingredient statement is present,
the label may also state the percentage of certified organic ingredients. All other organic claims are prohibited. Below
is an example of an acceptable spirits label in this category:

CUCUMBER FLAVORED

Since 2009

CUCUMBER FLAVORED There are many artisinal vodkas

in today’s market.
There’s only one smooth and
silky cucumber flavored premium
vodka that also supports local
organic farmers and helps
protect the environment.

PREMIUM Bottled by Common Good Distillery

Washington, DC
1 Ingredients: Water, rye, organic
cucumber, yeast
2 96 percent organic content
GOVERNMENT WARNING: (1) ACCORDING
TO THE SURGEON GENERAL, WOMEN SHOULD
NOT DRINK ALCOHOLIC BEVERAGES DURING
PREGNANCY BECAUSE OF THE RISK OF BIRTH
DEFECTS. (2) CONSUMPTION OF ALCOHOLIC
BEVERAGES IMPAIRS YOUR ABILITY TO DRIVE
COMMON GOOD DISTILLERY A CAR OR OPERATE MACHINERY, AND MAY
DISTILLED FROM GRAIN CAUSE HEALTH PROBLEMS.
ALCOHOL 40% BY VOLUME 750 ml

Why the label is acceptable

1. The USDA organic seal isn’t present on the label, and organic claims are limited to the ingredient statement.
2. Since the voluntary ingredient statement is present, the percentage of organic ingredients claim is acceptable.

5
LABELING ORGANIC DISTILLED SPIRITS

To increase labeling compliance, here are two examples of unacceptable labels we’ve seen and how to correct them.

Unacceptable Labels: Example 1

A certifier/ACA confirms that this vodka contains water, organic rye (96%), cucumber (3.5%) and yeast (0.5%).

CUCUMBER FLAVORED

Since 2009

3
CUCUMBER FLAVORED There are many artisinal vodkas
in today’s market.
There’s only one smooth and
silky cucumber flavored organic
vodka that also supports local
organic farmers and helps
protect the environment.
MADE
WITH ORGANIC RYE
Imported by Spirit International
Washington, D.C.
Product of Estonia
Certified organic by
1 IT-BIO-999 2
GOVERNMENT WARNING: (1) ACCORDING
TO THE SURGEON GENERAL, WOMEN SHOULD
NOT DRINK ALCOHOLIC BEVERAGES DURING
PREGNANCY BECAUSE OF THE RISK OF BIRTH
DEFECTS. (2) CONSUMPTION OF ALCOHOLIC
BEVERAGES IMPAIRS YOUR ABILITY TO DRIVE
1 EURO COMMON GOOD LTD. A CAR OR OPERATE MACHINERY, AND MAY
DISTILLED FROM ORGANIC GRAIN CAUSE HEALTH PROBLEMS.
ALCOHOL 40% BY VOLUME 750 ml

Why is the label unacceptable?

1. In the “organic” category, all agricultural ingredients must be certified organic except per the National List. This
vodka contains non-organic cucumber and yeast; the cucumber must be certified organic and yeast must be
certified organic unless it is not commerically available in organic form. Therefore, this vodka isn’t eligible for
the “organic” category and the European Union (or UDSA) organic logo can’t be used anywhere on the label.
2. The certifier/ACA’s full name isn’t included.
3. In the “made with organic rye” statement, words must be formatted the same (and no more than half the size
of the largest text on the label).

How can I correct it?

1. Remove the European Union organic logo from the label.
2. Identify the certifier/ACA (“certified organic by ***”), spelling out the certifier/ACA’s full name (not just the
code assigned by the European Union).
3. Reformat the “made with organic rye” statement so that all words are formatted the same.
6
LABELING ORGANIC DISTILLED SPIRITS

Unacceptable Labels: Example 2

Testing confirms that this vodka contains water, organic rye (96%), organic cucumber (3.4%), and yeast (0.6%). The
finished vodka isn’t overseen by a certifier/ACA.

CUCUMBER FLAVORED

Since 2009

FLAVORED WITH
ORGANIC CUCUMBER 1 There are many artisinal vodkas
in today’s market.
There’s only one smooth and
silky cucumber flavored premium
vodka that also supports local
organic farmers and helps
protect the environment.

PREMIUM Bottled by
Common Good Distillery
Washington, DC
ABC Certified organic by
CERTIFIERS
ABC Certifiers, Inc. 2

GOVERNMENT WARNING: (1) ACCORDING

TO THE SURGEON GENERAL, WOMEN SHOULD
NOT DRINK ALCOHOLIC BEVERAGES DURING
PREGNANCY BECAUSE OF THE RISK OF BIRTH
DEFECTS. (2) CONSUMPTION OF ALCOHOLIC
BEVERAGES IMPAIRS YOUR ABILITY TO DRIVE
COMMON GOOD DISTILLERY A CAR OR OPERATE MACHINERY, AND MAY
1 DISTILLED FROM ORGANIC GRAIN CAUSE HEALTH PROBLEMS.
ALCOHOL 40% BY VOLUME 750 ml

Why is the label unacceptable?

1. While the rye/grain and the cucumber are certified organic, the finished vodka isn’t overseen by a certfier/ACA.
Therefore, you can only make organic claims in the ingredient statement (see page 5).

2. Since the finished product isn’t overseen by a certifier/ACA, a certifier/ACA’s name or logo can’t be on the label.

How can I correct it?

1. Change the commodity statement to “distilled from grain” and change “flavored with organic cucumber“ to
“cucumber flavored.”

2. Remove the “certified organic by ***” statement, as well as the certifier/ACA’s logo.

If the label includes an optional ingredient statement, it can also state, “contains 99 percent organic ingredients” below
the ingredient statement.