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The TTB and Social Media

The TTB (Alcohol and Tobacco, Tax and Trade Bureau) recently issued new guidelines relating to Social Media use by wineries and brands. The Industry Circular dated May 13, 2013 can be seen in full here.

In essence, the TTB has classified Social Media as advertising, and now requires that any wine, beer, or liquor producer follows the same guidelines for Social Media outlets that apply to other forms of media (e.g. print, billboard, television). The areas specific to wine are §§ 4.62 and §§ 4.64. These regulations have been in place for a number of years for other forms of advertising.

The most important part of the circular is contained in the second paragraph of Section 2 – Authority – and reads as follows “More specifically, the regulations contained in §§ 4.62, 5.63, and 7.52 require certain mandatory statements (e.g., responsible advertiser name and address) to appear in advertisements for wines, distilled spirits, and malt beverages, respectively, and the regulations contained in §§ 4.64, 5.65, and 7.54 prohibit certain advertising practices and statements from appearing in such advertisements.”

The TTB has produced a general “What you should know about Alcohol Advertising” brochure that is available here. This brochure references some key items prohibited in alcohol advertising on any medium, now including Social Media. In their words, “Generally speaking the regulation prohibit”:

• Statements that are false or untrue.

• Statements that are inconsistent with approved product labels.

• False or misleading statements that are disparaging to a competitor’s product.

• Health related statements that are false or misleading.

• Misleading guarantees (although money back guarantees are not prohibited).

Mandatory Statement

The mandatory statement requires that the “advertiser” state their name and address in all alcohol advertising. With regard to the May 13th circular for Social Media we have seen the following efforts to comply with these.

As seen on the Robert Mondavi Facebook Page:

As seen on The Light Grape (Accolade Wines) Facebook Page (and also used on YouTube):

As seen on The Light Grape (Accolade Wines) Pinterest Page (also used on Twitter due to limited space):

Outside Content

The TTB circular also references content that you might use or link to on your Social Media outlets. They state that all sites you reference also need to be in compliance with the TTB regulations on Social Media as advertising.

YouTube and Videos

It also appears that all video content a winery uploads onto YouTube would need to individually comply with the regulations. Given that these videos can be taken and embedded in other places like blogs, the TTB is placing the responsibility of compliance on the video producer for both their YouTube channel, and each video.

Seek Legal Advice

If you are unsure of any of the above, seek legal advice.

 




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Wine Market Council
PO Box 2012
Saint Helena, 94574
USA

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