Everyone’s pals at the Alcohol Tobacco and Trade Bureau sent a reminder for beverage alcohol makers: Once your label is approved, you are allowed to change certain items on that label without obtaining a new COLA (TTB Form 5100.31 – Application for and Certification/Exemption of Label/Bottle Approval). Examples include:
- Changing the net contents statement
- Deleting non-mandatory label information
- Adding, changing or deleting bottle deposit information
Any revisions you make to your approved labels must be in compliance with the applicable regulations in 27 CFR parts 4, 5, 7 and 16, and any other applicable provision of law or regulation, including the conditions described in the “Comments” section of the chart of allowable revisions.
Changes that always require a new COLA
You must get a new COLA when changing:
- The class or type statement (product designation)
- The brand name
- The appellation of origin (wine only)
- The state appearing in the mandatory address statement. The new state must be reflected on the industry member’s basic permit, brewer’s notice or other qualifying documents
- The actual bottler or importer
You must get a new COLA when changing or adding:
- Graphics, pictures or representations (except as specifically authorized, for example, holiday themed graphics)
- Wording, phrases, text, certifications (except as specifically authorized, for example, serving instructions)
Bottom line, if you are considering making changes to previously approved labels, it’s just good practice to review the complete list of allowable revisions before you submit a COLA application because you may not need to send the revised labels at all.