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Industry Circular: 14-02

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Alcohol and Tobacco Tax and Trade Bureau

Industry Circular

Number: 2014-02
Date: September 29, 2014

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Expansion of Allowable Revisions to Approved Alcohol Beverage Labels

To: Proprietors of Bonded Wineries, Bonded Wine Cellars, Taxpaid Wine Bottling Houses, Beverage Distilled Spirits Plants, Breweries, Importers, and Others Concerned.

1. Purpose.

The Alcohol and Tobacco Tax and Trade Bureau (TTB) is further expanding the list of changes that may be made to approved labels without requiring those labels to be resubmitted to TTB for review. Currently, industry members may make certain changes to approved alcohol beverage labels without submitting a new TTB Form 5100.31, Application for and Certification/Exemption of Label/Bottle Approval, under the guidelines outlined on the form in Section V, “Allowable Revisions to Approved Labels.” We are committed to minimizing administrative burdens on the industry, while carrying out our mission to protect the public.

2. Authority.

Section 105(e) of the Federal Alcohol Administration Act (FAA Act), 27 U.S.C. 205(e), provides for the application for and issuance of certificates of label approval (COLAs) for wine, distilled spirits, and malt beverages sold, shipped, or otherwise introduced in interstate or foreign commerce and authorizes the Secretary of the Treasury to prescribe regulations for the labeling of such products. TTB administers the regulations promulgated under the FAA Act, which are set forth in Title 27, Code of Federal Regulations (CFR), parts 4, 5, and 7 (27 CFR parts 4, 5, and 7). The FAA Act requires that these regulations, among other things, prohibit consumer deception and the use of misleading statements on labels, and ensure that labels provide the consumer with adequate information about the identity and quality of the product.

3. Labeling.

Industry members may make certain changes to previously approved alcohol beverage labels without applying for a new COLA. There are currently 28 allowable revisions, which may be found on the COLA form. Furthermore, TTB has announced in various rulings and guidance documents that specific changes to labels may be made without resubmitting labels for approval. See, e.g., Industry Circular 2014-1, “New Argentine Wine Labeling Rules and Certificate of Label Approval Requirements.”

Effective on the date of this circular, the following additional changes may be made to a previously approved label without submitting a new application for label approval. As reflected in the numbering of the following changes, TTB plans to add these changes to the COLA form when it is next revised.

Any revision(s) you make to your approved label(s) 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. The revisions must also comply with the conditions described in the "Comments" section of the chart.

Please note that additional label changes, for example, repositioning existing label information in order to accommodate new information, must be made in compliance with TTB regulations and with the allowable revisions instructions listed on the COLA application form, TTB Form 5100.31 (which also appear on COLAs Online for electronic submitters), and may require filing a new COLA application.

Additional allowable revisions to approved labels:






29. Delete or change promotional sponsorship-themed graphics, logos, artwork, dates, event locations and/or other sponsorship-related information (e.g., sports leagues, team organizations, annual sporting events, and annual or semi-annual festivals).




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).

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.




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.




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.”




A sulfite statement is required when sulfur dioxide or a sulfiting agent is detected at a level of 10 or more parts per million, measured as total sulfur dioxide. The statement used must accurately reflect all of the sulfur dioxide or sulfiting agent(s) present in the alcohol beverage. For wine: Any other variation of the statement or removal of the statement requires a lab analysis. For sulfite waivers, the proprietor must have proof of sample analysis from a TTB-certified laboratory or from the TTB Compliance Laboratory.

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




Example: “100 bottles produced.”

34. Add certain instructional statements to the label(s) about how best to consume or serve the product. Only the statements listed in the comments section may be added.




Only the following statements are approved to be added to a label:
“Refrigerate After Opening”
“Do Not Store In Direct Sunlight”,
Best If Frozen For ___ to ___ Hours”,
“Shake Well”,
“Pour Over Ice”,
“Best When Chilled”,
“Best Served Chilled”,
“Serve Chilled”,
“Serve at Room Temperature”


If you have any questions concerning this circular, please contact the Advertising, Labeling and Formulation Division at 1-866-927-2533 or alfd@ttb.gov.

John Manfreda

John J. Manfreda
Alcohol and Tobacco Tax and Trade Bureau

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Last updated: March 5, 2024