WineXpert Formula approval for wine kits

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Highland

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New winery owner who is frustrated with the TTB label approval process. I already have 18 labels approved and in the notes box I have stated the wine kit that is used for each wine. I did not have to submit a formula for any of them. Now the feds say I do. Anybody know where I can find the statements of process for WineExpert juices?
Thanks in advance for any guidance. I just find the whole label process a challenge because it seems like it is very inconsistent.
 
For something like this I would recommend contacting WineExpert for advice. I would not be surprised if they help.
 
I doubt that any kit manufacturer will divulge their kit mix. I owned a commercial winey and investigated the issue you are struggling with. First question do any of your labels use a varietal name to describe the wine or are you using a fanciful name? IF varietal then the formula request is valid as it must state on the label the percent content. if a fanciful name and a designation as a table wine then a formula should not be required.
I used an outfit called US Elite Winery Supplies, which I believe is owned by one of the kit suppliers, who sells kit wines at quite a discount and will provide a certificate of validity that the varietal content sated for the kit is 75% of the kit juice. I would use the varietal name on the label as it conforms to the 75% rule and kept the certificate on file along with the batch details in the event of a audit.
I visited with a winery in Indianapolis whose entire wine supply was kits. he followed the fanciful name concept.
another problem you may have is one individual approved your initial labels and another has come along and over ruled the first individual, which means to me that an interpretation is going on. if you can get them on the phone maybe you can resolve.
 
Please keep us updated on this. We are just starting out and I am curious how this issue resolves itself.
 
I am using the fanciful name because I ran into the varietal issue during my first label approval. I already have 18 labels approved and then I run into this issue on number 19. I talked with a TTB agent today and she looked at the label and said it should be OK. So I will push it through again with a note to the specialist describing my fermentation process and hope for approval.
 
It is as I surmised. the approval process is unfortunately in the hands of different agents. there interpretations will vary. I am glad that you could successfully reach a TTB agent. It came to mind that there should be a regional agent that you could access easier then the label approval group. Good luck and stick to you guns.
 
Label approval received

It looks like the conversation with the TTB agent helped. I resubmitted the label with a note to the specialist that similar labels have been approved and the corrected submission was approved today.
 

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