Rogoway Law Secures TTB Approval for Baga on American Wine Labels

For wineries looking to use Baga on their American wine labels, we have exciting news: Rogoway Law Group successfully petitioned the Alcohol and Tobacco Tax and Trade Bureau (TTB) to add Baga to the list of administratively approved grape variety names for American wines.³

What is Baga?

Baga is a distinguished red wine grape variety from Portugal that is very common in Bairrada, a Portuguese wine-growing region (Denominação de Origem Controlada or DOC). According to renowned wine authority Jancis Robinson’s “Wine Grapes” (Robinson, J., Harding, J., & Vouillamoz, J. F., 2012), Baga is considered one of Portugal’s most significant indigenous varieties, accounting for over 90% of red grape plantings in its home region of Bairrada.

Key Characteristics of Baga:

Often referred to as the “Portuguese Nebbiolo” by wine critics like Matt Kramer of Wine Spectator, Baga produces wines with distinctive characteristics:

• Small deep ruby to garnet color berries with notably thick skins
• Often compared to Pinot Noir and Nebbiolo in its site sensitivity and complexity
• High natural acidity and  tannin structure contribute to excellent aging potential, often improving for 10-20 years in proper conditions
• Known locally as “berry” or “droplet” (the meaning of “Baga” in Portuguese)
• Officially recognized synonyms include Tinta Bairrada, Tinta Fina, and Tinta Poeirinha

The Approval Process

The TTB maintains strict requirements for grape variety names under 27 CFR 4.23 ³ and 27 CFR 4.93 ², which require:

• Evidence that the grape variety is accepted
• Validation of the grape variety name
• Proof of the variety’s use in winemaking
• Confirmation of its cultivation in the United States

Our legal team at Rogoway Law Group successfully navigated this regulatory process, resulting in Baga’s administrative approval by the TTB.

Current Status and Usage Requirements

With Baga receiving administrative approval from the TTB, wineries can immediately begin using this designation. While the TTB will still conduct a final rulemaking process, they are currently accepting and approving labels with Baga as a varietal designation. Specifically, wineries can:

1. Use “Baga” as a varietal designation when meeting the requirements of 27 CFR 4.23(b)⁴:
   • The wine contains at least 75% Baga grapes
   • The grapes are grown in the labeled appellation of origin
2. Include Baga in multi-varietal wine names with appropriate percentage listings
3. Market their wines to consumers interested in Portuguese varieties

Need Help with Grape Variety Approvals?

At Rogoway Law Group, we specialize in helping wineries navigate TTB regulations and secure approvals for new grape varieties. Our successful petition for Baga demonstrates our expertise in this complex regulatory landscape.

Contact our wine law attorneys today to learn how we can help expand your labeling options and bring new grape varieties to the American wine market.

Note: This blog post reflects the current status of TTB administrative approval for Baga as of February 2025. Final rulemaking may affect these requirements.

Reference

1. Robinson, J., Harding, J., & Vouillamoz, J. F. (2012). Wine Grapes. HarperCollins.
   
2. U.S. Alcohol and Tobacco Tax and Trade Bureau. (2025). 27 CFR §4.93 – Approval of grape variety names. Code of Federal Regulations. Retrieved from https://www.ecfr.gov/current/title-27/chapter-I/subchapter-A/part-4/subpart-J/section-4.93
   
3. U.S. Alcohol and Tobacco Tax and Trade Bureau. (2025). Grape Variety Designations on American Wine Labels. Retrieved from https://www.ttb.gov/regulated-commodities/beverage-alcohol/wine/grape-variety-designations-on-american-wine-labels#administrative_approval
   
4. U.S. Alcohol and Tobacco Tax and Trade Bureau. (2025). 27 CFR §4.23 – Varietal (grape type) labeling. Code of Federal Regulations. Retrieved from https://www.ecfr.gov/current/title-27/chapter-I/subchapter-A/part-4/subpart-C#4.23