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TTB NEWSLETTER | Weekly News

April 20, 2018


IN THIS ISSUE

Greetings! This week's top news includes Teresa Knapp's selection for a new position in TTB, and reminders about changes you may make to previously approved alcohol beverage labels without getting a new COLA.

TERESA KNAPP SELECTED AS DISTRICT DIRECTOR, WESTERN II, TRADE INVESTIGATIONS DIVISION

Teresa Knapp, who has served as an assistant director in the Alcohol Labeling and Formulation Division (ALFD) since 2003, is moving west to fill the vacancy left when Ken Klein recently retired as District Director of the Western II Trade Investigations Division (TID) field office.  The Western II TID office covers northern California, Washington, Oregon, Idaho, Montana, Alaska, Hawaii, and Guam.  Ms. Knapp reports to her new position on May 14, 2018.

While working in ALFD, Ms. Knapp spent time leading the wine labeling office, the formula team, as well as most recently serving as the assistant director over the malt beverage and distilled spirits labeling office. She is known by many in the alcohol beverage industry for her enthusiasm and dedication to providing excellent customer service.

Stephen Robey will temporarily serve as Assistant Director over both formulation and malt beverage/distilled spirits labeling while we search for a permanent replacement for Ms. Knapp.

REMINDERS ABOUT CHANGES YOU MAY MAKE TO APPROVED ALCOHOL BEVERAGE LABELS WITHOUT GETTING A NEW COLA

Once your label receives TTB approval, you are allowed to change certain items on that label without obtaining a new COLA (TTB Form 5100.31 - Application for and Certification/Exemption of Label/Bottle Approval). Any revisions you make to your approved labels must be in compliance with the applicable regulations in 27 CFR parts 4, 5, 7 and 16, and any other applicable provision of law or regulation, including, but not limited to, the conditions described in the "Comments" section of the chart of allowable revisions.

What Label Revisions Always Require a New COLA?

You must get a new COLA when changing:

  • the class or type statement (product designation)
  • the brand name
  • the appellation of origin (wine only)
  • the state appearing in the mandatory address statement*
  • the actual bottler or importer

You must get a new COLA when changing or adding:

  • graphics/pictures/representations (except as specifically authorized, for example, holiday themed graphics)
  • wording/phrases/text/certifications (except as specifically authorized, for example serving instructions)

If you are considering making changes to previously approved labels, please review the complete list of allowable revisions before you submit a COLA application—you may not need to send us the revised labels at all!

* The new state must be reflected on the industry member's basic permit, brewer's notice, or other qualifying documents.

 

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