Two Ways Into the US for an Alcohol-Free Wine

The 0.5% line decides the route. At 0.5% alcohol or more, your wine is an alcoholic beverage in America, and in most states it reaches bars, restaurants, and wine shops through an importer and a distributor. Below 0.5%, the FDA regulates it as food. In most states you can then sell it from the first shipment, while a distributor is still deciding: in your own online store, on Faire and Airgoods, in coffee shops and yoga studios, and on Amazon, which asks for its approval when a wine is above 0.0%.

Key Takeaways

• The 0.5% line decides which law applies. From 0.5% alcohol by volume, a wine pays federal excise tax and must bear the government health warning. Below it, the wine is food under FDA rules.
• An appellation wine stays above the line. EU rules let a wine with a PDO or PGI be partially de-alcoholised only, so it reaches America as an alcoholic beverage. A fully de-alcoholised Vin de France can reach it as food.
• Below 0.5%, in most states, the wine can sell from the first shipment. It can go into your own online store, onto Faire and Airgoods, and into shops with no alcohol licence straight away, and onto Amazon, which approves the seller first when a wine is above 0.0%.
• Food rules still apply. FDA facility registration, prior notice for every shipment, a Foreign Supplier Verification Program, FDA labelling, and California's deposit on de-alcoholised wine.
• Selling direct tells you who drinks your wine. An order in your own store arrives with a name, a city, and a date, and in our experience that record is the first thing a distributor asks to see.

Where Your Wine Sits on the 0.5% Line

Take two wines from the same house. One is fully de-alcoholised and sold as a Vin de France. The other is partially de-alcoholised and keeps its appellation. Europe decides which is which before America does.

EU law lets a wine with a protected designation of origin or protected geographical indication lose only part of its alcohol. The appellation rules do not apply to a wine that has undergone total de-alcoholisation (Regulation 1308/2013, Article 92(1)), and the Commission reads that as meaning PDO and PGI wines "can thus only be partially de-alcoholised" (Commission Notice C/2024/694, question 16). On the label, "de-alcoholised" means no more than 0.5% alcohol by volume, and "partially de-alcoholised" means above 0.5% (Article 119(1)(a)). The appellation wine sits above 0.5%. The Vin de France can sit below it.

America also draws its line at 0.5%. A beverage with 0.5% alcohol by volume or more is an "alcoholic beverage" under the federal labelling law, and an imported one must bear the government health warning (27 CFR 16.10, 16.20, 16.21). Imported wine pays federal excise tax (27 CFR 27.42), and a wine under 0.5% is not taxable as wine (27 CFR 24.10; TTB, Federal Regulation of Low and No Alcohol Beverages, slides 13 and 26). Below 0.5%, the FDA treats a de-alcoholised wine as food and applies the food labelling rules (FDA CPG Sec. 510.400). The two lines meet at one point: a wine at exactly 0.5% is "de-alcoholised" under EU labelling and an alcoholic beverage in America.

A second federal line sits at 7%. From 7%, an imported wine needs a certificate of label approval from TTB, and its importer needs a federal basic permit (27 CFR 4.40, 1.10, 1.20). Below 7%, those rules do not reach the wine, and its label follows FDA food rules (27 CFR 4.7(a)). A partially de-alcoholised wine at 3% still pays excise and bears the warning, and in most states it is sold as alcohol.

The Alcohol Route

In most states, a wine at 0.5% or more reaches an American drinker through three businesses: an importer, a distributor, and the bar, restaurant, or shop that pours or sells it. This is the three-tier system, and each state runs its own version of it (how the three-tier system works).

The distributor is the business that matters most to you. It buys your wine and resells it to the licensed accounts in its state. In our experience, a distributor asks to see months of sales before it takes on a new brand. A new alcohol-free wine has none to show yet.

For a partially de-alcoholised wine, this is the main route. A wine under 0.5% has a second one.

The Food Route

Below 0.5%, the FDA regulates your wine as food, and in most states the alcohol laws, with their three tiers, do not apply (state-by-state rules). The wine can sell from the first shipment.

Where You Can Sell

• Your own online store, shipping to the drinker's door (selling direct to consumers).
• Amazon. Its alcohol policy permits "Non-alcoholic beverages with 0% alcohol-by-volume", and a wine above 0% and under 0.5% only when "sold by pre-approved selling partners" (Amazon Seller Central, Alcohol). A 0.0% wine can list from the start; a wine labelled under 0.5% needs Amazon's approval first (selling on Amazon, when Amazon gates a listing).
• Faire and Airgoods, where shops and grocers order wholesale from brands (how Faire works).
• Coffee shops, yoga studios, and other shops that hold no alcohol licence.

The State Exceptions

Tennessee keeps wine under 0.5% inside its alcohol law. Its definition takes beverages under 0.5% out of regulation "other than wine" (T.C.A. § 57-3-101(a)(1)(A), as set out in the Tennessee Department of Revenue's Alcohol Tax Manual, June 2026, page 10). Kentucky's definition includes "every spurious or imitation liquor sold as, or under any name commonly used for, alcoholic beverages, whether containing any alcohol or not" (KRS 241.010(2)), so its position on an alcohol-free wine is unsettled; ask Kentucky's Department of Alcoholic Beverage Control in writing. Our state-by-state table marks a few more states to confirm before you sell there.

What Still Applies

Food has its own rules, and they start before the first pallet leaves.

• The winery registers with the FDA as a food facility and names a US agent (21 CFR 1.225, 1.232(c); registration and the US agent). The FDA charges no fee (21 CFR 1.231(c)).
• Every shipment needs prior notice, confirmed by the FDA before arrival: at least eight hours ahead by sea and four by air (21 CFR 1.277, 1.279; filing prior notice).
• The wine's importer in America, as the FDA defines it, runs a Foreign Supplier Verification Program for it (21 CFR 1.500, 1.502; FSVP explained).
• The label follows FDA food rules (21 CFR part 101). FDA guidance asks for "dealcoholized" or "alcohol-removed" before the word "wine", followed by "contains less than 0.5 percent alcohol by volume". "Non-alcoholic" may appear as an extra claim, and "alcohol-free" is kept for a wine with no detectable alcohol (CPG Sec. 510.400; US labelling).
• California's deposit, the CRV, covers "wine from which alcohol has been removed, in whole or in part" (Cal. Pub. Res. Code § 14504(a)(11); deposit rules by state).