The TTB and USDA entered into a memorandum of understanding (MOU) regarding the use of the term "organic" on alcoholic beverage labels and advertisements. Pursuant to the MOU, the TTB will still be responsible for analyzing alcoholic beverage labels and advertising, but will review all claims of "100% organic", "organic" and "made with organic (ingredients)" to see if they meet USDA National Organic Program guidelines.
COLAs for wine, beer and spirit labels that contain "organic" claims will now be approved by the TTB as "approved subject to compliance with the Organic Foods Production Act of 1990 and the National Organic Program regulations[.]" If they do not comply with USDA organic laws, the labels will be rejected and the TTB will let applicants know what changes need to be made to make the label compliant. An applicant may only appeal this rejection with the USDA’s Agricultural Marketing Service.
A copy of the MOU is available here: