What Does It Take to Change a Beer Label Once It Gets Approved?

As the owner of Compliant Bootlegger LLC, I have become fluent in considering my clients’ needs and delivering them the best guidance on various compliance issues in the alcoholic beverage sphere. We handle a broad scope of issues at Compliant Bootlegger including the intricacies and frankly confusing language surrounding beer label laws.

In this blog post, I will cover one of the most common questions we receive: “Do I need to apply for a new Certificate of Label Approval if something is changed on our beer label?”

The answer to that question is not as straightforward as one might think. The most common response we provide is: “It depends.”

The Alcohol and Tobacco Tax and Trade Bureau (TTB for short) is part of the U.S. Department of Treasury, and its purpose is to regulate and collect taxes on the trade and imports of tobacco, alcohol and firearms in the United States. The TTB’s licensing rules are confusing enough within the three-tier system, so when it comes to alcohol label approval, it’s only fitting that the TTB created an even more confusing system for that task.

This system, called the Certificate of Label Approval (or COLA), provides the TTB with all the pertinent details of a beer or other alcoholic beverage. According to the TTB, the following information must be present on all beer labels in the U.S.:

1- Brand Name
2- Class and Type Designation
3- Name and Address
4- Net Contents
5- Alcohol Content
6- FD&C Yellow #5 Disclosure
7- Saccharin Disclosure
8- Sulfite Declaration
9- Aspartame Disclosure
10- Health Warning Statement
11- Country of Origin

After all of this information has been provided, the TTB will approve the label for release. However, when a beer manufacturer decides to make a change with their already approved label, it might be necessary for them to apply for a new COLA, but how do you know if this is the case? 

Do you need a new COLA if you change the artwork on a label?  What about the description/story or the brand name of the beer itself? These are all valid questions, and once again, it depends.

One rule of thumb: When any of the mandatory information above is changed, it is a solid bet that you will need to apply for a new COLA. The good news is that the process is not all that difficult – it just takes time.

The TTB has set up an online application with step-by-step instructions in order to complete a COLA. One simply applies for an account by filling in the blanks, uploading some perfectly sized PDF files of the label, submitting the application and waiting about 6 days or so for an answer. Sometimes the COLA comes back “approved” and other times it comes back needing revisions – it all depends on your understanding of the process.

For those who do not care to decipher the foreign language of the TTB and COLA, we suggest you call us at Compliant Bootlegger to help assist you in these matters. Because we have ample experience in this area, sometimes it’s best to use a professional resource like us to aid you with these complex machinations.    

For those of you who chose not to use a professional and dare to brave the choppy waters of alcohol compliance laws and beer labeling by yourselves, we have supplied you with the “allowable” label changes link from the TTB.  But be warned, this is a dense and intense document, so when you do decide to read it, we suggest that you curl up on the couch in a comfy Snuggie with your favorite IPA. At least this way you might somewhat enjoy your reading (wink wink).

TTB ALLOWABLE LABEL CHANGES