All wines for sale in the United States that contain 10 or more parts per million (ppm) sulfur dioxide must bear a label stating "Contains Sulfites" (27 CFR 4.32(e)). This labeling requirement allows those people who may have an allergic reaction to sulfur dioxide to be aware of its presence in wines.
The Food and Drug Administration has determined that products that contain less than 10 ppm of sulfites (such as sulfur dioxide) do not have to include this declaration on the label or they can label the product with the statement "contains less than 10 ppm sulfites." These wines require a sulfur dioxide waiver for such labeling.
For sulfite waivers, the application for Certificate of Label Approval (COLA) must include an official laboratory report from a TTB laboratory. A laboratory report for sulfite waivers from a TTB certified chemist does not meet this requirement. The Chemist Certification Program is designed to facilitate exportation of alcohol beverages; chemists are certified to test wines for sulfites significantly above the low 10 ppm level needed for sulfur dioxide waivers. Producers and importers should contact the TTB Beverage Alcohol Laboratory to request a sulfite waiver analysis for submission with their COLA application.
How to Submit Samples for Sulfite Waiver Testing
If you are a producer or importer, you may request a sulfite waiver analysis for wine by submitting the following to our Beverage Alcohol Laboratory:
TTB Beverage Alcohol Laboratory
6000 Ammendale Road
Beltsville, MD 20705
- An official letter from the producer or importer with a request for sulfite waiver analysis
- The identity of the product being tested
- One 750 mL bottle of the finished wine for testing
After receiving all of the above items, the laboratory will complete testing (generally within 10 days from sample receipt), and send an official report to the submitter for inclusion with their application for label approval.