Bourbon & Spirits

How to Read a Whiskey Label: What the Federal Rules Actually Require

What the Federal Rules Actually Require

A US whiskey label is a legal document with a marketing job on the side. Federal rules in 27 CFR Part 5 decide what must appear, what key words mean and when an age must be printed, so the label tells you a lot once you know the vocabulary.

Quick facts

  • Brand name, class or type, and alcohol content must appear in one field of vision (one side of the bottle, readable without turning it).
  • Alcohol content must be stated as percent alcohol by volume (ABV). Proof is optional and equals twice the ABV.
  • Whisky under 4 years old must carry an age statement, unless it is bottled in bond.
  • "Straight" means at least 2 years in new charred oak with no added coloring or flavoring.
  • "Bottled in bond" means one distilling season, one distiller, one distillery, at least 4 years in wood, bottled at 100 proof.
  • Every bottle also carries the federal "GOVERNMENT WARNING" statement, worded exactly as the regulations require.

Class and type: the name of what you are drinking

Every spirits label must state a class and type. "Whisky" is the class. "Bourbon whisky", "rye whisky", "straight bourbon whisky" and "corn whisky" are types, each with a standard of identity in 27 CFR 5.143.

Bourbon must come from a mash of at least 51 percent corn, be distilled at no more than 160 proof, go into new charred oak containers at no more than 125 proof, and contain no added coloring, flavoring or blending materials. Like all whisky, it is bottled at 80 proof or higher. "Whisky" alone promises less. For the full rule set, see What is bourbon?.

Proof vs ABV

The mandatory number is ABV, written as something like "45% alc/vol". Proof is optional, but if it appears it must sit in the same field of vision as the ABV. In the US, proof is ABV doubled, so 45 percent ABV is 90 proof.

The allowed tolerance is plus or minus 0.3 percentage points. Whatever the number, a measured pour and a splash of water are a good way to taste.

Age statements: when they are required

Federally, age is time spent in oak barrels between distillation and bottling. Tank and bottle time do not count.

If a whiskey is younger than 4 years, the label must state its age, except when it is bottled in bond. The standard format is "___ years old", and age may also be given in months or days. When whiskeys of different ages are combined, the stated age must be that of the youngest. Understating age is allowed. Overstating it is not.

At 4 years or older, an age statement is optional. Whiskey stored in reused oak barrels uses different wording: "stored ___ years in reused cooperage".

What "straight" means

"Straight" is a defined type, not a flavor note. A straight bourbon or straight rye was distilled at 160 proof or less and stored at 125 proof or less in charred new oak for at least 2 years, with no neutral spirits and no added coloring, flavoring or blending materials. It can be a mixture of straight whiskeys made in the same state.

Combine that with the age rule: straight whiskey with no age statement is at least 4 years old. More in Straight bourbon.

Bottled in bond

Under 27 CFR 5.88, bottled in bond spirits must be:

  • the same kind, distilled from the same class of materials;
  • distilled in one distilling season (January to June, or July to December), by one distiller, at one distillery;
  • stored at least 4 years in wooden containers;
  • reduced only with pure water and bottled at 50 percent ABV (100 proof).

The label must show the name under which the spirits were distilled, plus the plant number (DSP number) where they were distilled and the plant number where they were bottled.

"Distilled by", "produced by" and "bottled by"

These phrases come from 27 CFR 5.66. Each names a different role; none ranks above another.

  • Distilled by names the distiller and its address. If the spirits were bottled for the distiller, "distilled by and bottled for" or "bottled for" may be used.
  • Bottled by (or "canned by", "packed by", "filled by") names the company that filled the container. On its own, it does not say who distilled the contents.
  • Produced by, like "blended by", "made by", "prepared by" and "manufactured by", names a processor. For spirits, the regulation says "produced by" indicates processing that changes the class or type, such as adding flavors.

The address is the city and state where the work happened (or the principal place of business) and must match the federal permit. When different companies did different steps, the label may not suggest one did them all.

State of distillation

For most American whiskey types (bourbon, rye, wheat, malt, rye malt, corn, their straight versions, whisky distilled from a named mash, and American single malt), the label must disclose the state where the whiskey was originally distilled. That can be done with:

  • a "distilled by" statement listing a single location;
  • a "bottled by" address in the state of distillation;
  • the state name next to the type, such as "Kentucky straight bourbon whisky", which requires that it was both distilled and aged in that state;
  • a separate line such as "Distilled in Indiana".

"Finished in" statements

Part 5 does not define "finished", but TTB has said how it reads one. Bourbon must mature in new charred oak, so a bourbon that then spends time in a used cask (sherry, port, stout, tequila) no longer fits the bourbon standard on its own. TTB treats it as a distilled spirits specialty and expects the label to say what happened in plain words, such as "bourbon whisky finished in sherry casks." A label that just says "bourbon" and hides the cask in the small print is not enough. Any age statement still reflects the youngest whiskey in the bottle. See Cask finished whiskey.

Net contents

Bottle size must appear in metric units, such as 750 ml, and only sizes authorized by 27 CFR 5.203 (including 50 ml, 375 ml, 700 ml, 750 ml, 1 L and 1.75 L) may be used.

FAQ

What is the difference between proof and ABV on a whiskey label?

ABV is percent alcohol by volume, the figure federal rules require. Proof is optional and is twice the ABV, so 50 percent ABV is 100 proof.

Does whiskey have to have an age statement?

Only if it is under 4 years old, unless it is bottled in bond. Older whiskey may state an age but does not have to. When whiskeys are combined, the age shown is that of the youngest.

What does "bottled by" mean on a whiskey label?

It names the company that filled the bottle. It does not by itself indicate who distilled the whiskey; for most American whiskey types, the label must separately disclose the state of distillation.

How old is straight bourbon with no age statement?

At least 4 years. Straight bourbon must age at least 2 years, and whiskey under 4 years must carry an age statement, so one without a statement has 4 or more years in oak.

Sources

  1. 27 CFR 5.143, Whisky standards of identity (eCFR)
  2. 27 CFR 5.74, Statements of age (eCFR)
  3. 27 CFR 5.66, Name and address and state of distillation (eCFR)
  4. 27 CFR 5.88, Bottled in bond (eCFR)
  5. Examples for ADI Conference, August 26, 2024 (TTB)
  6. Anatomy of a Distilled Spirits Label (TTB)

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