For many manufacturers, designing labeling and branding is never truly final. Designs, branding, addresses, and dates often change. Additionally, basic product details may evolve since the label was initially approved by the Alcohol and Tobacco Tax and Trade Bureau (“TTB“). Fortunately, you may not always need to resubmit your label to the TTB for every change.
The TTB allows for over 40 types of permissible changes to approved labels. Whether your change qualifies depends on several factors, including the nature of the amendment and the classification of your product as a wine, distilled spirit, or malt beverage.
What is an Allowable Change?
The TTB currently has over 40 allowable changes that are permitted to be made without formally notifying TTB through a new Certificate of Label Approval (“COLA”) process. Some allowable revisions include the following:
- Adding, deleting, or changing the signature of the brewer, distiller, or winemaker.
- Adding, deleting, or changing optional information about awards or medals.
- Adding, deleting, or changing website address, phone number, fax number, or zip code.
- Adding, deleting, or changing instructions about opening a boxed wine container.
- Adding, deleting, or changing tap instructions for opening a keg.
- Deleting any non-mandatory label information, including text, illustrations, graphics, etc.
- Removing all organic references from the label (provided no other organic references remain on the labeling or advertising).
These allowances can be quite specific. For instance, a manufacturer may add certain instructional statements on how to best consume or serve the product without needing resubmission for approval, but only specific instructions such as “Refrigerate After Opening,” “Shake Well,” and “Serve Chilled” are permitted.
Understanding these nuances can help you keep your labels compliant while adapting to changes efficiently. A common misconception in the alcohol beverage world is that TTB allows the addition of non-mandatory language without a new COLA. Generally speak, TTB does not actually allow the addition of non-mandatory language without the creation of a new COLA.
How Can Lindsey Zahn P.C. Assist with TTB’s Allowable Revisions?
Navigating the complexities of label changes and revisions can be a daunting task for manufacturers in the alcohol beverage industry. At Lindsey Zahn P.C., we focus on providing professional guidance to ensure your labels remain compliant with the Alcohol and Tobacco Tax and Trade Bureau (“TTB”) regulations. Whether you’re updating branding, modifying product details, or making necessary adjustments, our team is here to help you every step of the way.
- Personalized Consultation: We offer personalized consultations to understand the specific changes you need and determine whether they qualify as allowable changes under TTB guidelines.
- Detailed Review: Our firm will meticulously review your proposed label changes to ensure they comply with all regulatory requirements, helping you avoid potential setbacks.
- Efficient Processing: We assist in preparing and submitting the necessary documentation to the TTB, streamlining the process to ensure your updated labels are approved promptly.
- Ongoing Support: From initial consultation to final approval, we provide continuous support and advice, helping you navigate any challenges that arise.
Whether you’re adding new information, updating branding elements, or making other adjustments, Lindsey Zahn P.C. ensures your label changes are handled efficiently and correctly. Contact us today at info@zahnlawpc.com or 929-924-6529 to learn how we can assist with your label revisions and keep your products in compliance with TTB regulations.