ESTABLISHMENT OF NEW SYSTEM OF APPLYING FOR CERTIFICATE OF
LABEL APPROVAL UNDER THE FEDERAL ALCOHOL ADMINISTRATION ACT
Proprietors of distilleries, rectifying plants,
taxpaid bottling houses, breweries, and
bonded wine cellars; wholesalers, and
importers; and others concerned:
Purpose. The purpose of this circular is to familiarize you with the
September 1957 revision of Form 1649, application for and certificate of label
approval under the Federal Alcohol Administration Act.
Background. Heretofore this office has required the submission of labels
covering alcoholic beverages on Form 1647. Application for Certificate of
Label Approval Under the Federal Alcohol Administration Act. Pursuant to
this form a certificate of label approval has been issued to the applicant on
Form 1649, Certificate of Label Approval Under the Federal Alcohol Administration Act. The revised form combines Form 1647 and 1649 on one sheet
of paper and will be used by all applicants in lieu of Form 1647 and prior
revisions of Form 1649.
Procedure. This form will be executed in accordance with specific instructions contained thereon and will be submitted, in duplicate, by the applicant to the Director, Alcohol and Tobacco Tax Division, Internal Revenue
Service, Washington 25, D. G.
With this new form, if the labels are in compliance with the regulations,
the Director will sign and return to you one of the copies submitted, retaining
the other for the Division's files. This procedure will provide a much more
expeditious manner of handling the vast number of label approval applications
received and should overcome the often serious delays under the old system
where the certificate of approval had to be prepared in full by this office. If
you are located a great distance from Washington and urgent approval is
necessary, it is suggested that you enclose a self-addressed, pre-stamped
air mail envelope, otherwise return of the certificate will be by regular mail.
The instructions on the form should be followed explicitly. If the form is
not properly executed, or if the labels are not properly affixed or properly
identified, as in Instruction C, it will be necessary to return the forms for
re-execution even though the labels themselves may be in compliance with
The form contains nine items to be filled in. Items 2 through 8 must be
filled in by the applicant. Item 1 may be filled in by the applicant, if he wishes;
some firms have found it desirable to serialize their labels (as A-1, A-2,etc.)
for reference purposes and simplifying exchange of correspondence with this office. Item 9 is for the use of the Government only and must not be filled
by the applicant. It will be noted on the reverse side of the form that there
a space for the date of approval and for the applicant's serial number if one is
used. You may fill these spaces in when the certificate is returned so that in
photostating, only one side of the certificate need be reproduced.
Submission of an unnecessary number of applications may be avoided by
careful study of the coverage of the certificate outlined under the heading
"Certificate of Label Approval". For example, many firms still submit
separate applications for labels which differ only in proportionate size or by
reason of a change in the statement of net contents. A reading of the coverage
clause will show that this is not necessary.
With reference to Item 2 on the application portion of the form, your true
name or operating name must always be shown. In addition, if your permit contains one or more bottling trade names and you use one of these names on the
label in lieu of your true or operating name, insert, additionally, the one
bottling trade name that is used on the label submitted. The address shown in
Item 2 must be that of the plant where the bottling will take place. However, if
you wish a certificate mailed to some other address, this information must be
included in Item 7.
Under Item 6, state any wording, other than indicia information, blown or
etched in the bottles or otherwise appearing on the container, as for example,
on caps or cello seals. It is desirable to mark the use of such wording as
"optional", so that it will not be necessary to resubmit an application in case
you use plain glass, or plain caps, or plain cello seals. In some instances
small brochures or pamphlets are affixed loosely to the neck of the bottle with
the idea that they will be detached and read by the consumer; such brochures
or pamphlets will not be required to be made a part of the label application,
provided they are submitted for letter approval in advance of use.
The revised form contains an important innovation with regard to wine
labels which will reduce the number of certificates necessary. In Instruction
E, authorization is contained to obtain approval for wine-type designations in
addition to the designation on the label submitted. These additional designations,
as well as the designation on the label submitted, must be included in Item 5-B.
This procedure is permissible only for labels that are identical in all respects
except for the type designation. For example, a change of alcoholic content on
the label, even if the wine is in the same taxable grade, would not be covered
under the procedure outlined in Instruction E. All of the type designations you
submit, and which are approved, will be typed on the back of the approval
certificate under "Remarks". We reserve the right to disapprove any one or
more of the proposed additional designations, if the finished label, as a whole,
would not be proper under the regulations for use with the type designation
In the case of wines, further simplification has been made by eliminating
submission of formulas for formula wines in a limited number of cases (see
Instruction D-2). These exceptions apply only if you are the maker of the
formula wine; the formula for purchased wine and the date of its approval must
still be obtained from your supplier and submitted with the application. The
exceptions, allowing formula wines to be submitted without a formula, apply
only to Vermouth and to naturally sparkling wines (other than Champagne)
made by yourself. Formulas for artificially carbonated wines must be submitted, as well as formulas for bottle-process and bulk-process Champagne.
formulas for all flavored still wines (other than products designated
"Vermouth") must continue to be submitted; for example, formulas must be
submitted for wines designated "Aperitif Wine", "May Wine", "Retsina",
and for wine specialties designated with statements of composition.
While the instructions contemplate submission of only two copies of this
form, some firms prefer to have duplicate copies for their main office files.
In such cases, submit 3 copies of the form, each fully executed, with labels
properly affixed, with the notation "Duplicate Certificate Requested".
Applications for certificates of exemption from label approval will continue to be submitted on Form 1648, Application for Certificate of Exemption
from Label Approval Under the Federal Alcohol Administration Act.
Copies of the September 1957 revision of Form 1649 may be obtained
from the Office of the Assistant Regional Commissioner, Alcohol and Tobacco
Tax, in your respective region, on or about September 1, 1957.
Inquiries. Correspondence in regard to this Industry Circular should refer
to the number thereof and to the Symbols O:AT:BP.
Dwight E. Avis
Director, Alcohol and Tobacco Tax Division