Certificate of Label Approval

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Alcohol and Tobacco Tax and Trade Bureau (TTB) official Susan Evans, the Executive Liaison for State and Industry Matters, talked about ways to streamline the federal label approval process at the June 2013 National Conference of State Liquor Administrators (NCSLA) that I attended in Honolulu. Speaking on a panel, she said that the TTB has experienced reduced staffing and declining budgets, which have slowed down two of its major functions: permitting and approving labels. 

According to Ms. Evans, nearly 25,000 permittees submit certificate of label approvals (COLAs) to TTB . Last year TTB received over 145,000 COLA applications. In the last two years, TTB has imposed fewer restrictions and qualifications, updated the COLA form to allow changes that may be made to labels without TTB approval, and established a virtual file room for processing paper applications electronically. 

In addition, TTB recently reviewed the label approval program and concluded the following:Continue Reading Federal Officials Mull Changes to Alcohol Label Approval Process

The Alcohol and Tobacco Tax and Trade Bureau (TTB) has experienced some difficult times in the last several years due to reduced staffing and declining budgets. These factors have made it difficult for the agency to accomplish two of its major functions; Permitting and Approving Labels.

TTB has attempted to address the Label Approval issue by instituting two recent changes. First in April 2011, the agency announced that would discontinue evaluating labels for purposes of ensuring that the labels conform to all applicable legibility and type size requirements (including characters per inch and contrasting background). As always, the responsible industry member is obligated to ensure proper labeling for their products and this new procedure ensures new label approvals will contain a statement to that effect.

Then on July 5, 2012, TTB published a revised version of TTB Form 5100.31, Application for and Certification/Exemption of Label/Bottle Approval, also known as a certificate of label approval or COLA. The most significant change made was to expand the list of items that may be changed on an alcohol beverage label without TTB approval. Highlights of the new revisions include the following. Holders of approved labels may:Continue Reading TTB Addresses Label Approval Issues

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The Stoel Rives Alcohol Beverage Blog provides wineries, breweries, distilleries, cideries, distributors and importers with articles and information across a broad spectrum of state and federal alcohol beverage law. The authors work on alcohol beverage related projects from our bases in California, Oregon and Washington, throughout the Western United States and beyond.