Obtaining a Certificate of Label Approval (COLA) can be a headache for alcohol beverage industry members. Before launching your product, labels must be approved by the Alcohol and Tobacco Tax and Trade Bureau (TTB).
However, the TTB recently expanded its list of allowable revisions to labels. This means that if you make a change to your product’s label, it is helpful to first consult the list of allowable revisions before resubmitting the label for approval. Your label may not require a new review at all. This is to ensure additional flexibility for industry players while reducing the number of labels that must be resubmitted for approval.
Four new provisions
Industry members may now make the following revisions to their labels:
- You may add, change or remove instructions to open a boxed wine container.
- You may add, change or remove instructions on how to tap a keg.
- You may add, change or remove a label containing the name and/or address of the container manufacturer. This is applicable for wine, distilled spirits and malt beverages.
- You may change the numerical representation stated on a malt beverage label of the International Bitterness Units or Original Gravity.
The TTB also expanded on two existing provisions. These include changes to the color and cosmetic makeup of the label, changes to combining separate approved labels and changes to adjusting claims that the product is environmentally or eco-friendly.
The importance of reviewing allowable revisions
There are now 41 allowable revisions on the TTB’s list. When your label has already been approved, reviewing the full list of allowable revisions can save you time and energy before resubmitting a label that you’ve made relatively minor changes to.
Alcohol beverage industry members are required to remain in compliance with a wide range of restrictions. When in doubt, consulting with an alcoholic beverage law attorney here in Florida can be helpful.