Revision of ATF Form 1649 - Application for and Certification of Label Approval Under the Federal Alcohol Administration Act.

Proprietors of Distilled Spirits Plants, Bonded Wineries, Taxpaid Wine Bottling Houses, Breweries, Importers, and Others Concerned:

Purpose. This circular announces an extensive revision of Form 1649, Application for and Certification of Label Approval under the Federal Alcohol Administration Act.

Background. The Distilled Spirits Council of the United States (DISCUS) submitted a petition to ATF to revise Form 1649 to reduce the number of appli- cations filed with ATF by allowing a single label approval for multiple plants and by increasing the number of changes which can be made to a label without refiling for approval. Many aspects of the DISCUS petition have been adopted in addition to further changes to help streamline processing and simplify retrieval of approved certificates from ATF records. The nature of each revision is discussed below.

Multiple Filing. The instructions have been revised to permit filing a single application for multiple locations where identical labels are used. One additional copy of the application must be submitted for each additional location.

Vendor Code. A vendor code is assigned to each applicant. These codes aid us in identifying the applicant and retrieving documents from our record- keeping system. Most industry members know their own vendor code, so we have revised the form to require applicants to show their own vendor code on the form. This will expedite processing appli- cations. New applicants will be assigned a vendor code on their first application, for use on all subsequent applications.

Formula Number. Applicants will be required to show the formula number for products having formu- las. This will help us expedite processing, by eliminating the need to qualify certificates.

Format Changes. Part I of the form has been modi- fied to accommodate the three changes discussed above.

Instructions. In addition to the changes discussed above, an instruction is added to clarify the term Brand Name. We have had some difficulty retrieving documents from our recordkeeping system when one brand name is used for more than one product. Therefore, we are asking applicants to provide further identification in the brand name box, for brand names used for more than one product.

Conditions for Approving Labels. We have revised the conditions under which a label may be changed without requiring a new application, as follows:

1. The shape of a label may be changed.

2. The name and/or address of the responsible importer may be changed.

3. The name and/or address of the foreign producer, bottler or shipper may be changed if the producer, bottler, or shipper is located in the same country originally shown.

4. The condition which previously read "In period of age stated or in statement of age and per- centage of distilled spirits" has been con- verted to two separate conditions for clarity.

5. For wines, the stated amount of harvest or residual sugar, acid or pH level may be changed.

Effective Date. After October 1, 1979, applica- tions will not be accepted on old editions of ATF Form 1649.

Availability of Forms. Please destroy all stocks of old editions of ATF Form 1649 and obtain a supply of the new edition from ATF Distribution Center, 3800 South Four Mile Run Drive, Arlington, VA 22206.

Questions. Any questions about this Industry Cir- cular should refer to its number and be addressed to the Assistant Director (Regulatory Enforcement), Bureau of Alcohol, Tobacco and Firearms, 1200 Pennsylvania Avenue, NW., Washington, DC 20226.

Director

GPO 943-394