TTB Announces Expansion of List of Changes for Prior Approved Labels

Today, the Alcohol Tobacco Tax and Trade Bureau (“TTB”) announced that it has further expanded the list of changes that may be made to approved labels (or COLAs) without requiring those labels to be resubmitted to TTB for review. Currently, industry members are permitted to make certain changes to approved alcohol beverage labels without applying for a new COLA under TTB guidelines entitled “Allowable Revisions to Approved Labels.” As of today, the following additional changes may be made to labels without re-submittal of previously approved labels: 1) Delete or change promotional sponsorship-themed graphics, logos, artwork, dates, event locations and/or other sponsorship-related information; 2) 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; 3) Delete all organic references from the label; 4) Change an approved sulfite statement to certain approved options included on TTB guidance; 5) Add, delete, or change information about the number of bottles that were “made,” “produced,” “brewed,” or “distilled” in a batch; respectively; 6) Add certain instructional statements to the label(s) about how best to consume or serve the product (only approved statements listed within the TTB guidance may be included).

For more information or for assistance with labeling or COLAs questions, please contact Bahaneh Hobel at here.