It has come to our attention recently that certain alcohol beverage wholesalers believe that TTB requires them to maintain copies of Certificates of Label Approval (COLAs) for all products that they maintain on their premises. 27CFR, Part 4.30 (wine), 5.51 (distilled spirits), and 7.31 (malt beverages), outline label approval and release requirements. TTB does not require wholesalers to maintain this type of information. However, if the wholesaler is also an importer, the importer must have a COLA for each product imported.
Distillers, wineries, breweries and importers of alcohol products are expected to comply with the various labeling requirements set forth in the applicable parts of 27 CFR. Administrative action can be taken if violations of these requirements are disclosed during the course of a TTB field investigation. However, absent any evidence of involvement/collusion with either the producer or importer, TTB, as a matter of policy, would not cite a wholesaler for a label violation that was incurred as a result of either the producer's or importer's removal of the product from the premises without an approved COLA. Any sanctions that may be taken would be imposed on the producer or importer responsible for complying with applicable labeling regulations.