Aging mead in barrels is one of the best things about being a meadery. But labeling those products has been one of the most frustrating things about being a meadery.
Here’s what the TTB currently says about aging meads in barrels:
- Pursuant to 4.38, if barrel aging is claimed as part of the brand label (the big part on the front where you say what the mead is, e.g. “mead aged in oak barrels,” a length of aging statement is considered part of the “complete and accurate” clause.
- So you can say “Mead aged in oak barrels for 10 months”
- Or you can put a range, such as “Mead aged in oak barrels for 9-12 months”
- If it’s in puffery section, or on a back label, no length statement is required.
- According to a policy guidance document pending approval, but being currently observed, the type of spirit barrel can be stated on the brand as part of the statement of composition.
- So you can say “Mead aged in whiskey barrels for 9-12 months”)
- That statement can’t mislead the customer by seeming to claim more spirit than wine. So we can’t write “mead aged in BOURBON barrels”)
- Standard agricultural wine cannot contain spirits, of course.
As always, a COLA exemption is a different animal, and one can write any truthful aging statement one wants on an exempted label, so long as that product will not be used in interstate commerce.
Also as always, there is always the potential for the person reviewing your label to be unfamiliar with the fairly arcane intricacies of these rules. If a label is returned, you believe in error, please reference this page in your conversations.
