Containers

Label and adhesive

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The requirement Why it exists What it rules out The conditions it has to survive Which usually means a wet-strength face stock Brief the supplier on the regulation, not the bottle And test it the way a bar will The same test protects the front label Application matters as much as adhesive References

"Cannot be removed without thorough application of water or other solvents" is a purchasing specification.

The requirement

Labels are affixed to containers of alcoholic beverages in such manner that they cannot be removed without thorough application of water or other solvents.

Why it exists

A label that lifts can be moved to another bottle. The requirement is about the integrity of what the label says as much as about presentation.

What it rules out

A removable or repositionable adhesive, and a low-tack stock chosen so that a label can be straightened during application. Both are ordinary choices elsewhere and neither is available here.

The conditions it has to survive

Refrigeration, condensation running down the glass, an ice bucket, a wet bar towel and months of handling. The adhesive has to stay aggressive through all of that and still be hard to lift afterwards.

Which usually means a wet-strength face stock

A paper that goes soft when wet takes the decision out of the adhesive’s hands. The face and the adhesive are one specification and should be quoted as one.

Brief the supplier on the regulation, not the bottle

Quote the requirement. A label house that works in spirits knows exactly what it means; one that does not will quote you a general-purpose permanent adhesive that has never seen an ice bucket.

And test it the way a bar will

Chill the labelled bottle, submerge it, leave it, dry it, and try to lift a corner with a thumbnail. If it comes away cleanly, the specification is not met, whatever the data sheet says.

The same test protects the front label

A lifted brand label is a presentation failure and a compliance one at the same time, because the field of vision requirement assumes the label is still attached.

Application matters as much as adhesive

A permanent adhesive applied to a cold or damp bottle never reaches its full bond. Labelling at room temperature on a dry bottle, and giving the adhesive time before the cases are stacked, is half the specification.

References

27 CFR 16.22, legibility of the health warning. Minimum type size of 1 mm for containers of 237 mL or less, 2 mm above that through 3 L, and 3 mm above 3 L; "GOVERNMENT WARNING" in capitals and bold with the remainder not bold; characters not compressed, at a maximum density of 40 characters per inch at 1 mm falling to 12 at 3 mm; readily legible under ordinary conditions on a contrasting background; and labels affixed "in such manner that they cannot be removed without thorough application of water or other solvents". law.cornell.edu

27 CFR 5.63, mandatory label information. Brand name, class and type designation and alcohol content appear in the same field of vision, so that "all of the pieces of information can be viewed simultaneously without the need to turn the container". Name and address and net contents may appear anywhere on the container, and the net contents "may be blown, embossed, or molded into the container". law.cornell.edu

Written from 27 CFR 5.63, 5.203, 16.21 and 16.22, and from the catalog as it stood on 17 October 2026. Distilled spirits are federally permitted and separately regulated by every state; label approval, permits and formula approval are outside what these pages cover, and nothing here is a substitute for TTB guidance on a specific product.