In the complicated 85 years since Prohibition was repealed the US, the Alcohol and Tobacco Tax and Trade Bureau (TTB) has tried to consistently regulate wine sales in what are effectively 50 different markets with very different needs.

California grapegrowers have long sold their fruit both in and out of state. However, in a complicated turn of events how the resulting wine made from that fruit is labeled has been legally dependent on whether that wine was only sold in the state where it was produced or outside of it as well.

A legal loophole, called note No. 160 or 160B, was recently breached by a non-California winery and its legality is being called into question. This loophole – prior to this rift – allowed producers outside of California to label wines made from California fruit with California AVAs. They were legally able to do so by requesting an exemption to a certificate of label approval.