List of Allowable Changes to Approved Labels

Approved Brand Label

Approved Brand Label With Allowable Changes
(No Need To Obtain COLA)

Approved Back Label

Approved Back Label With Allowable Changes
(No Need To Obtain COLA)

YOU MAY...

REVISION APPLIES TO

COMMENTS

WINE

DISTILED SPIRITS

MALT BEVERAGE

1. Delete any non-mandatory label information, including text, illustrations, graphics, etc.

YES

YES

YES

If the non-mandatory information in question relates to other information that remains on the label, it is your responsibility to ensure that the remaining information is not misleading after the deletion.

2. Reposition any label information, including text, illustrations, graphics, etc.

YES

YES

YES

The repositioning must comply with any placement requirements applicable to mandatory information. For example, some types of mandatory information must appear on the brand label or must appear together with other label information.

3. Change the color(s) (background and text), shape and proportionate size of labels. Change the type size and font, and make appropriate changes to the spelling (including punctuation marks and abbreviations) of words, in compliance with the regulations. Change from an adhesive label to one where label information is etched, painted or printed directly on the container and vice versa. 

Divide a single approved label into multiple labels on a container, or combine separate labels that were approved under a single COLA into a single label on a container, provided that the label or labels comply with any applicable placement requirements for mandatory information and all other relevant requirements.

YES

YES

YES

All changes must comply with applicable regulations, and changes in spelling must not change the meaning of the previously approved information. All mandatory information must be readily legible and appear on a contrasting background. Any revisions that affect mandatory label information must also comply with placement rules and other applicable requirements for such information.

4. Change the stated percentages for blends of grape varietals and appellations of origin for wine labels.

YES

N/A

N/A

When used for any of these items, the total percentages for each element must equal 100%. You may not change the name of the stated varietals or appellations without submitting a new application.

5. Add, change or delete a vintage date for wine labels.

YES

N/A

N/A

If the vintage date is deleted, no reference to "Vintage" may be made on any label or other materials (e.g., caps, capsules, corks, etc.) affixed to the bottle. When adding a new vintage date, you must comply with all applicable regulations, including the requirements regarding appellations of origin.

6. Change the optional "produced" or "made" by statements on wine labels to "blended", "vinted", "cellared" or "prepared" by statements.

YES

N/A

N/A

7. Add, change or delete the stated amount of acid and/or the pH level for wine labels.

YES

N/A

N/A

8. Change the stated amounts of sugar at harvest and/or residual sugar for wine labels.

YES

N/A

N/A

See ATF Ruling 82-4 for policy regarding use of sugar content statements and when such statements are required.

9. Add or delete bonded winery or taxpaid wine bottling house number for wine labels.

YES

N/A

N/A

If used, a bonded winery number must appear in direct conjunction with the bottler's name and address.

10. Change the net contents statement.

YES

YES

YES

Revisions must comply with all applicable regulations governing net content statements and standards of fill. Please ensure that all applicable type size requirements are met for each container size.

11. Change the mandatory statement of alcohol content, as long as the change is consistent with the labeled class and type designation and all other labeling statements.

YES

YES

YES
(Flavored
Malt Beverages Only)

For example, you may change the alcohol content of a grape wine labeled with a varietal designation from 13 percent to 15 percent alcohol by volume, even though it results in a change to the product’s tax classification.

However, if the product was designated and labeled as a “table wine,” an alcohol content of 15 percent alcohol by volume would be inconsistent with the rules for use of that designation, so this change would not be permitted.

12. Add, delete, or change an optional statement of alcohol content for malt beverage labels.

N/A

N/A

YES

Malt beverages that contain alcohol derived from added flavors or other added nonbeverage ingredients (other than hops extract) containing alcohol are subject to mandatory alcohol content statement requirements.

13. Change the statement of percentage of neutral spirits and the name of the commodity from which a distilled spirit is produced.

N/A

YES

N/A

These changes must not result in a change to the class or type designation of the distilled spirits product.

14. Change the mandatory age statement, or delete or change an optional age statement for distilled spirits labels.

N/A

YES

N/A

These changes must not result in a change to the class or type designation. See 27 CFR 5.141 through 5.166 and 27 CFR 5.74 for further information about age statements and minimum aging requirements applicable to certain classes and types of spirits.

15. Delete or change an optional age statement, including a barrel aging statement, for wine and malt beverage labels.

YES

N/A

YES

Statements of age on wine labels must comply with 27 CFR 4.39(b).

16. Add, delete, or change statements or information in order to comply with the requirements of the State in which the malt beverage is to be sold.

N/A

N/A

YES

Applies only to malt beverages sold in that particular State (including the District of Columbia or the Commonwealth of Puerto Rico).

17. Add a new Serving Facts statement or statement of average analysis, add a Serving Facts statement to replace a statement of average analysis, or change the numerical values for calories, carbohydrates, protein, and fat contained in an existing statement.

YES

YES

YES

The statement must be in compliance with TTB Ruling 2013-2 and TTB Ruling 2004-1.  A new Serving Facts statement is an allowable revision only if it is in one of the formats that is set forth in the examples attached to TTB Ruling 2013-2.

18. Add, delete, or change stated bottling date, production date (day,month,and/or year) or freshness information including bottling, production or expiration dates or codes.

YES

YES

YES

Bottling dates added to wine labels must comply with 27 CFR 4.39(c).

19. Change the name or trade name to reflect a different name already approved for use by the responsible bonded wine cellar, taxpaid wine bottling house, distilled spirits plant, brewery, or importer. Change the address where it is within the same State.

YES

YES

YES

This means that a bonded wine cellar, taxpaid wine bottling house, distilled spirits plant, brewery or importer may revise the label to include the use of a name or trade name that is already approved for that particular industry member. The name or trade name must appear on the basic permit, brewer’s notice, or other qualifying documents for the company to whom the original certificate was issued. If the name or trade name is also used as the brand name on the label, resulting in a change of brand name, you must submit a new application. The change in address is ONLY allowed for in-state moves or other changes to the COLA holder’s address that have already been reflected on the industry member’s basic permit, brewer’s notice, or other qualifying documents.

20. Add, delete, or change the name and/or address of the foreign producer, bottler, or shipper.

YES

YES

YES

The producer, bottler, or shipper must be located in the same country originally shown.

21. Add, delete, or change the name, address, and/or trademark of the wholesaler, retailer, or persons for whom the product is imported or bottled.

YES

YES

YES

22. Add, delete, or change bottle deposit information.

YES

YES

YES

23. Add, delete, or change UPC barcodes and/or 2D mobile barcodes, e.g., QR codes or Microsoft Tags.

YES

YES

YES

Addition or change of UPC Code must be in compliance with Industry Circular 77-23. Any information retrieved from 2D barcodes must be in compliance with all applicable advertising regulations.

24. Add, delete, or change a Web site address, phone number, fax number, or zip code.

YES

YES

YES

25. Add, delete, or change a lot or batch identification number or other serial numbers.

YES

YES

YES

26. Add, delete, or change trademark, copyright symbols (e.g., TM, ©, ®), kosher symbols, company logos, and/or social media icons.

YES

YES

YES

Symbols, logos and icons may not violate TTB regulations. Advertisements on social media sites must be in compliance with all applicable advertising regulations.

27. Add, delete or change optional information about awards or medals, or the signature of the brewer, winemaker, or distiller of the product.

YES

YES

YES

28. Add, delete, or change holiday- and/or seasonal-themed graphics, artwork and/or salutations.

YES

YES

YES

Holiday/seasonal-themed information or graphics must not conflict with or qualify the mandatory information and must comply with all applicable regulations, including the rules governing prohibited practices.

29. Delete or change promotional sponsorship-themed graphics, logos, artwork, dates, event locations and/or other sponsorship-related information (Examples: sports leagues, team organizations, annual sporting events, and annual or semi-annual festivals). Delete or change charitable endorsement information to include information about the proceeds.

YES

YES

YES

If authorization by a third party was required for use of such promotional sponsorship-themed information on a label when first approved, it is the responsibility of the industry member to have any necessary documentation of authorization to cover the revisions to the approved label(s). The labeling statements may not create a misleading impression.

30. Add, delete, or change a label or sticker that provides information about a rating or recognition provided by an organization (e.g., “Recognized as one of the top values in vodka by x Magazine” or “Rated as the best 2012 wine by x Association”), as long as the rating or recognition reflects simply the opinion of the organization and does not make a specific substantive claim about the product or its competitors.

YES

YES

YES

These statements or graphics must not conflict with or qualify any mandatory information and must comply with all applicable laws and regulations.  Substantive claims about the product or its competitors are not covered by this exemption.

31. Delete all organic references from the label.

YES

YES

YES

If you choose to delete one organic claim on a label on which you have received approval to make organic claims, then all organic claims, references, and certification statements must be deleted on the revised label. The deletion of individual references or certification statements is not permitted without a new COLA.

32. Change an approved sulfite statement to any of these options: “Contains Sulfites,” “Contains (a) Sulfiting Agent(s),” “Contains [name of specific sulfating agent],” “Contains Naturally Occurring and Added Sulfites,” or “Contains Naturally Occurring Sulfites.”

“Sulphites” may be used in lieu of “Sulfites.”

YES

YES

YES

A sulfite statement is required when sulfur dioxide or a sulfiting agent is detected at level of 10 or more parts per million, measured as total sulfur dioxide.

33. Add, delete, or change information about the number of bottles that were “made,” “produced,” “brewed,” or “distilled” in a batch; respectively.

YES

YES

YES

Example: “100 bottles produced.”

34.  Add, delete, or change between approved instructional statements about how best to consume or serve the product.  

YES

YES

YES

Only the following statements are approved to be added to a label: 

35.  Add, delete, or change between approved responsibility statements.

YES

YES

YES

Only the following statements are approved to be added to a label: 

36. Add, delete, or change between listed sustainable farming, environmental, and eco-friendly claims.

YES

YES

YES

These statements must not conflict with or qualify any mandatory information and must comply with all applicable laws and regulations.  It is the responsibility of the industry member to have any necessary documentation of authorization to cover the revisions to the approved label(s).
Only the following statements are approved to be added to a label: 

"Sustainable Farming"
"Sustainably Grown"
"Carbon Neutral"
"Environmentally Friendly"
"Vegan-Friendly"
"Eco-Friendly"
"Biodynamic"
"Salmon Safe"
"Don't Litter"
"Environmentally Conscious"
"Eco-Conscious"

37.  Add, delete, or change between approved food pairing recommendations.

YES

YES

YES

Only the following food pairing statements are approved to be added to a label: 

38. Add, change, or delete opening instructions for a box wine container. 

YES

YES

YES

The instructions may include graphics limited to showing the step-by-step guidance 

39. Add, change, or delete a statement providing tapping instructions for a keg.

YES

YES

YES

40. Add to, change on, or delete from the label or container the name (or name and address) of the container manufacturer.

YES

YES

YES

41. Change the stated numerical representation of the International Bitterness Units or Original Gravity

N/A

N/A

YES