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Industry Circular

Number: 77-23

Date: December 29, 1977

Department of the Treasury

Bureau of Alcohol, Tobacco and Firearms

Washington, DC 20226


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

Purpose. The purpose of this circular is to advise industry members that labels which have been approved for use on containers of distilled spirits, wine or malt beverages may not require new certificates of label approval or certificates of exemption from label approval when revised only by the addition of Universal Product Codes (U.P.C.).

Background. The recent introduction of the Universal Product Code system of item marking, pricing and inventory control in retail outlets has caused some confusion with respect to ATF's policy as to the necessity for the re- approval of sets of labels for distilled spirtits, wine and malt beverages which are presently covered by certifi- cates of label approval.

Conclusion. New certificates of label approval or certificates of exemption from label approval are not required for previously approved labels where: (1) the addition of the U.P.C. does not result in rearrangement, obliteration, obscuration or other revision of the mandatory infor- mation required under regulations promulgated pursuant to the Federal Alcohol Administration Act; (2) the U.P.C. mark is added as a separate label containing no other in- formation or (3) the U.P.C. mark is added as an extension of a previously approved label without affecting the original label. Non-mandatory information on an approved label may be repositioned to accommodate the Universal Product Code but may not otherwise be altered. Further, the Universal Product Code may be changed as necessary without obtaining new certificates of label approval.

Inquiries. Inquiries concerning this circular 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.

Rex Davis

Rex D. Davis Director

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