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TTB NEWSLETTER | Weekly News

November 15, 2019

IN THIS ISSUE

Greetings! This week we’re highlighting information about changes you can make to approved alcohol labels without getting a new COLA, and the temporary voluntary disclosure program for alcohol wholesalers and importers who have unreported changes in control or proprietorship.

DOES CHANGING A LABEL MEAN GETTING A NEW COLA?

Making changes to alcohol beverage labels is a common occurrence, but do you need to apply for a new Certificate of Label Approval (COLA) each time you change them?  Very often TTB does not require you to get a new COLA when you update a label, but it’s important to know the rules.

Changes that Don’t Require a New COLA

Once your label receives TTB approval, you may make certain changes to that label without obtaining a new COLA. We encourage you to take advantage of the allowable revisions and only apply for a new COLA if you have to.

Examples of allowable revisions include:

• Adding, changing, or deleting a vintage date
• Changing the net contents statement
• Deleting non-mandatory label information
• Repositioning information or graphics
• Adding, changing, or deleting a website address or social media icons

See the full list of allowable revisions for additional information and conditions.

Any revisions you make to your approved labels must be in compliance with the applicable regulations and the conditions described in the "Comments" section of the chart of allowable revisions.

Changes that Always Require a New COLA

You must get a new COLA when changing:

• Class or type statement (product designation)
• Brand name
• Appellation of origin (wine only)
• Actual bottler or importer

You must get a new COLA when changing or adding:

• Graphics/pictures/representations (except as specifically authorized, for example, holiday themed graphics)
• Wording/phrases/text/certifications (except as specifically authorized, for example, serving instructions)

If you are considering making changes to previously approved labels, please review the complete list of allowable revisions before you submit a COLA application—you may not need to send us the revised labels at all!

TIME IS RUNNING OUT TO MAKE VOLUNTARY DISCLOSURE OF UNREPORTED CHANGES IN CONTROL OR PROPRIETORSHIP

Through December 31, 2019, TTB is offering a temporary voluntary disclosure program (see Industry Circular 2019 – 2) to address wholesalers and importers of alcohol beverages who have undergone a change in control (a change in who controls a business) or change in proprietorship (a change in the person or entity that owns a business) but failed to file a new permit application within 30 days of the change, as required by law.

This temporary program provides a streamlined approach that allows eligible wholesalers and importers to simultaneously voluntarily disclose the unreported changes in control or proprietorship and file an application for a new permit while benefiting from the enforcement discretion described in section 6 of Industry Circular 2019 – 2.

Time is running out, so we encourage you to take advantage of this program while you still can.
Additional Resource:

Temporary Voluntary Disclosure Program Instructional Videos

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