Associations and state partners: Please feel free to share the article below in your newsletters, websites, and communications to educate your industry members on Federal label approval.
Have you ever wondered when, and how, to get label approval from the Alcohol and Tobacco Tax and Trade Bureau (TTB)? These quick tips will help you to get approval and stay compliant with Federal labeling requirements!
When is TTB label approval required?
Obtaining a certificate of label approval (COLA) from TTB is required for products that fall under the Federal Alcohol Administration Act (FAA Act). The FAA Act applies to the following products when they are sold, shipped, or otherwise introduced in interstate commerce:
- Distilled spirits
- Wines that contain 7% to 24% alcohol by volume
- Malt beverages (for example, beers that contain both malted barley, and hops)
Distilled spirits and wines (with an alcohol content from 7% to 24%) that are sold only within the state where they are bottled may qualify for a certificate of exemption instead of a COLA. Malt beverages that are only sold intrastate do not need a COLA or a certificate of exemption.
For domestic products, a COLA (or certificate of exemption) must be obtained by the bottler prior to bottling. This applies even when contracting with another entity to produce products for you: The bottler gets the COLA. For imported products, the importer must obtain the COLA prior to removal from Customs custody.
Wines containing less than 7% alcohol by volume and beers that do not contain both malted barley and hops do not need a COLA (or certificate of exemption) from TTB but may still be subject to labeling requirements of the Internal Revenue Code and Alcoholic Beverage Labeling Act administered by TTB and the Federal Food, Drug, and Cosmetic Act administered by the Food and Drug Administration.
When you want to make changes to an approved label, consult the complete list of allowable revisions—you may not need to send us the revised labels at all.
What are the requirements for label approval?
The requirements of the FAA Act and its implementing regulations vary for distilled spirits, wines, and malt beverages, but all labels must be truthful, not misleading, and include all mandatory information. Applications that do not meet these requirements will be returned for correction.
TTB’s website, TTB.gov, provides all the resources you need to understand labeling requirements. The Anatomy of a Label tool and Mandatory Information Checklist— found on TTB’s Distilled Spirits Labeling, Wine Labeling, and Malt Beverage Labeling pages—are particularly helpful, as is the topic-specific guidance. TTB also offers labeling overview videos on its Boot Camp Video Series page.
How do I get a COLA for my product?
You can apply for a COLA using COLAs Online. Once you’ve registered for an account, just follow the instructions and prompts for submitting your online application. If no corrections are needed, you're done. There is no fee to apply, and approval often takes less than a week!
Does my product also need formula approval?
Certain beverages require an approved formula to ensure proper classification. This includes products with added flavors, colors, or artificial sweeteners, as well as specific categories like flavored spirits and imported gins. To find out whether your product needs formula approval, simply answer a few questions in TTB’s online formula tool.
If required, you will need to obtain formula approval prior to applying for labeling approval. You can find everything you need to know about formula approval on TTB’s Formulation page, including how to apply. Note that you may need formula approval even if your product doesn’t require label approval.
Who can I contact for more information?
If you still have questions after reviewing the resources on TTB.gov, you can reach out to the Alcohol Labeling and Formulation Division on their contact form or by calling 866-927-ALFD (2533). Customer service representatives are available 8 a.m. to 4:30 p.m. ET, Monday - Friday (except for federal holidays).