Making Allowable Changes to Approved Labels

Posted 05/30/2013

You Can Make Certain Changes to Your Labels Without Obtaining a New Certificate of
Label Approval (COLA)

Proper labeling is an important source of information for consumers. Resources at our Labeling page can help take the mystery out of labeling regulations and procedures.

If you are an alcohol beverage industry member (such as an importer or bottler) and are considering making changes to your previously approved alcohol beverage label, please review our complete list of allowable revisions before you submit your certificate of label approval (COLA) application - you may not need to send us the revised label at all!

When we updated our COLA application, TTB Form 5100.31, Application for and Certification/Exemption of Label/Bottle Approval in July 2012, we expanded the list of items an alcohol beverage industry member can change on a previously approved label without TTB approval.

The idea behind the change is this: With a longer list of allowable revisions, we expect a decrease in the number of submitted label applications. With a decrease in the number of submitted label applications, we anticipate a faster review time for labels for new products and products with major changes.

A key component to the success of these changes is for industry members (or even consultants and attorneys practicing in the field) to know and understand the specific types of changes allowed for previously approved labels, and to exercise their freedom to make minor allowable changes to their labels without sending unnecessary requests for additional COLA approvals. With these changes, we anticipate industry may see a faster and easier application process in the future!

Additional Resources

• Allowable Revisions to Approved Labels Webinar Presentation [PDF, 4.4 MB, 39 pages]
  If you weren't able to attend TTB's "Allowable Changes to Approved Labels" webinar, here's your chance to view the presentation!
  
  
• Complete List of Allowable Revisions To Approved Labels
  View a more detailed guideline in chart form. The chart also contains the allowable changes on approved labels for malt beverages and distilled spirits.
  
  
• Updated Certificate of Label Approval Application Form Expands List of Allowable Changes) [PDF, 213 KB, 4 pages]
  Read our public guidance document (TTB Public Guidance 2012-2) for additional information about making allowable changes to approved labels.
  
  
• Voluntary Nutrient Content Statements in the Labeling and Advertising of Wines, Distilled Spirits, and Malt Beverages [PDF, 49 KB, 11 pages]
  Industry members will not need to apply for new label approval to add a "serving facts" statement or statement of average analysis if it conforms to the examples in TTB Ruling 2013-2.

Contact Us

If you have any questions about what is mandatory information and what is non-mandatory information, please consult the applicable regulations in 27 CFR parts 4, 5, 7 and 16 or contact our Alcohol Labeling and Formulation Division:

• By phone at 202-453-2250 or toll free at 866-927-2533:
  
  
• • Option 4: Distilled Spirits and Malt Beverage Labeling
  • Option 6: Wine Labeling
    
    
• Submit an Online Inquiry