Is It Necessary to Use Standard Fill Amounts for Wine?
If I found a vessel that I wanted to use for packaging wine but it was a little under the 187 ml fill, can I use that vessel but state on the label the exact ml?
The U.S. Alcohol and Tobacco Tax and Trade Bureau (TTB), which is a part of the U.S. Department of Treasury, regulates bottle sizes for alcoholic beverages. TTB standards of fill for wine containers state that wine containers “shall be so filled as to contain the quantity of wine specified in one of the standards of fill prescribed in §4.72,” which includes 187 ml. (See 27 Code of Federal Regulations §4.71.) The purpose of the regulations establishing uniform standards of fill for alcoholic beverages, according to TTB, is "to prevent a proliferation of bottle sizes and shapes which would inevitably result in consumer confusion and deception with regard to the quantity and net contents of the alcohol beverage package." (See 64 Fed. Reg. 6486-9 (Feb. 9, 1999).)
Production of wine and other alcoholic beverages for sale in commerce is a complicated and highly regulated business at both the state and the federal level, and getting it wrong can result in costly consequences. It is definitely not a DIY project. We recommend that you consult with qualified counsel before proceeding in this line of business.