Labeling errors are avoidable
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Labeling errors are avoidable

| Oct 27, 2020 | Alcoholic Beverage Law |

Nearly all alcohol beverage manufacturers know that their labels need to have a health warning statement if the beverage contains more than 0.5%. But the Alcohol and Tobacco Tax and Trade Bureau (TTB) recently announced it still regularly sees errors in Certificate of Label Approval/Exemption (COLA) applications. The warning language on the label must be verbatim, or it will get rejected.

It must read as the following:

GOVERNMENT WARNING: (1) According to the Surgeon General, women should not drink alcoholic beverages during pregnancy because of the risk of birth defects. (2) Consumption of alcoholic beverages impairs your ability to drive a car or operate machinery, and may cause health problems.

While it is understandable that some may not want to have this warning on their aesthetically appealing label, omitting the notice or changing it in any way will result in a rejection. Common mistakes returned for correction include:

  • Not putting “GOVERNMENT WARNING” in uppercase
  • Not putting “GOVERNMENT WARNING” in a bold font
  • Any change in punctuation, including periods, commas, parenthesis or colon
  • The warning language must be legible under normal conditions with a contrasting background that makes it easy to read.
  • The warning’s font should not be compressed – different bottle sizes have different sized fonts ranging from 1 to 3 millimeters.

The same goes for import products

Imported wines, beers or liquors should not include other countries’ specific health warnings involved with the consumption of alcoholic beverages. Instead, the import containers must have the U.S. warning label. The notable exception is packaging done before November 18, 1989. Upon request, the importers are responsible for providing evidence that the beverage was bottled before the above date.

Rejections can impact business

Issues like an improperly designed label can hold back a business trying to get a jump on competitors or lead to a bottleneck in getting the product to consumers. Importers and manufacturers can avoid labeling issues by consulting with an attorney specializing in beverage law here in Florida.

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