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List of Allowable Changes to Approved Labels

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When you want to make changes to an approved label, please review the complete list of allowable revisions before you submit your COLA application—you may not need to send us the revised labels at all!

Examples of Labels with Allowable Changes

The following sample labels illustrate examples of changes you are allowed to make to your approved label without obtaining a new COLA from TTB. The item numbers below correspond with the numbers on the list of allowable revisions to approved labels, which is found on pages 3 and 4 of the COLA form (TTB Form 5100.31).

These are examples of revisions allowed in the context of these specific labels. Review the complete list of allowable revisions and applicable conditions for more information about each change. A picture can be worth a thousand words!  Use the Allowable Changes Sample Label Generator tool which illustrates examples of approved labels.

Approved Brand Label

 

 

In this example, we made the following changes ("allowable revisions") to the approved brand label:

  • Removed lighthouse illustration (item 1)
  • Removed fanciful name "Guiding White" (item 1)
  • Changed shape of label (item 3)
  • Changed color of background and fonts 
    (item 3)
  • Added a vintage date 
    (item 5)
  • Changed alcohol content statement (item 11)

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

 

 

Approved Back Label

 

 

In this example, we made the following changes ("allowable revisions") to the approved back label:

  • Removed lighthouse illustration (item 1)
  • Changed shape of label (item 3)
  • Changed color of background and fonts 
    (item 3)
  • Changed "Produced by" to "Vinted by" (item 6)
  • Changed net contents statement (item 10)
  • Changed address within same state (item 19)
  • Added a QR Code
    (item 23)
  • Added a Web site address (item 24)

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

 

 

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Complete List of Allowable Revisions To Approved Labels

Once a label receives TTB approval, you can make certain changes to that label without obtaining a new COLA from TTB. You can view and print the complete list of allowable revisions on pages 3 and 4 of the COLA form (TTB Form 5100.31).

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, including, but not limited to, the conditions described in the "Comments" section of the chart on the COLA form (TTB Form 5100.31).

 

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

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Last updated: April 6, 2024
Maintained by: Alcohol Labeling and Formulation Division