NOTICE OF REVISION OF FORM OF CERTIFICATE OF LABEL APPROVAL FOR ALL
ALCOHOLIC BEVERAGES AND OF NEED FOR RESUBMITTING ALL LABELS RELATING
TO DISTILLED SPIRITS FOR REAPPROVAL NOTWITHSTANDING ANY APPROVALS
GRANTED PRIOR TO JULY 1, 1968.
Proprietors of Distilled Spirits Plants, Bonded Wine Cellars, Taxpaid Wine
Bottling Houses, Brewers, Importers of Distilled Spirits, Wines and Malt
Beverages, Wholesalers Engaged in Relabeling Distilled Spirits and Wines,
and to others concerned:
The purpose of this Industry Circular is to advise you of new administrative procedures found necessary to be established by the Alcohol and Tobacco
Tax Division in connection with the issuance of certificates of label approval
under the provisions of the Federal Alcohol Administration Act [27 U.S.C. 205
In implementing these new procedures, this Division finds it necessary to
request all bottlers of distilled spirits, importers of bottled distilled spirits, and those permittees who relabel bottled distilled spirits, to resubmit all
of their labels currently in use for reapproval, notwithstanding the fact that
such labels have been approved in the past. Later on, bottlers of wine and
importers of bottled wine will be asked to do the same. Eventually, it is planned to ask brewers and importers of bottled beer to similarly cooperate.
The reasons for these new procedures are as follows:
1. The Alcohol and Tobacco Tax Division is establishing a system of microfilming all of its label approval records to conserve valuable office space.
This is something that must be faced by the Division. No other alternatives
are available to it. Each year, some 50,000 applications are processed. Considering that this activity is of more than 30 years' duration, it will be seen
that the accumulation of paper is most impressive and that this accumulation
must be reduced. Incidentally, a great deal of this volume relates to labels no
longer in use. There is little doubt that industry is also confronted with
considerable "deadwood" in its files of label approvals. Many labels have been
redesigned while others have been discontinued, thus rendering obsolete all of
the certificates relating to the superseded and discontinued labels. Good
management dictates that some housecleaning is in order at both Government and
industry levels to update their respective files.
2. In the past year, the alcoholic beverage industries have jointly agreed on
the need for a universal numeric code for, among other things, the classification of alcoholic beverages and the identity of vendors, to facilitate the
gathering of data for the development of statistical information for industry
purposes. The Alcohol and Tobacco Tax Division has been requested by these
industries to assist in this project to the extent of assigning product identification and vendor code numbers to all certificates issued by it so as to assure
uniformity in the identification and classification of products by the industry
members (who are being or will be requested to submit statistical data for this
industry project). This the Division has agreed to do.
New Form of Application for Label Approval
A new form has been devised which is so arranged that all essential information-as well as the labels-will be on one side of the form. This was found
necessary for purposes of microfilming. This new form will include space for
the numeric codes described above, which will be assigned by the Division for the convenience of industry members who will be called upon to participate in
this industry project. Obviously, when the new form is placed in use, the
old forms must be discontinued, and all supplies of the old forms (those now
in use) should be destroyed.
Effective Date of New Procedure
All new applications for approval of labels for distilled spirits, wines,
and malt beverages, will be made on the new form on and after July 1, 1968.
A supply of the revised form will be available in A&TT field offices about
June 15. The new form will be identified by a 1968 revision date and will be
readily recognized by its new design, notwithstanding the fact it will be
identified by the same number (No. 1649).
Special Provisions Found Necessary with Respect to Distilled Spirits
As to labels covered by certificates of label approval for distilled
spirits issued prior to July 1, 1968, all bottlers of distilled spirits and
importers of bottled distilled spirits (as well as those who relabel bottled
distilled spirits) will be expected (within a period of 12 months thereafter)
to have all of their labels currently in use reapproved by resubmitting all
of these labels on the new form. Certificates of label approval which have
been limited to specific operative dates should not be included. It is
important that this be done as early as possible during this period of transition so that the Alcohol and Tobacco Tax Division will not be faced with an
insurmountable workload at the end of the period of transition. All of the
applications that are resubmitted for the reapproval of previously approved
labels should be identified (by covering letter) as resubmissions of previously
approved labels. Industry cooperation is earnestly solicited in this regard.
Disposition of Previously Issued Certificates of Label Approval for Distilled
Certificates of label approval for distilled spirits products, issued
prior to July 1, 1968, will serve no useful purpose after July 1, 1969. They
may be retained, for historical purposes, by the holders thereof, or, at the
end of this period of transition, they may be destroyed. After July 1, 1969,
the files of the Division, as well as those in the Federal Records Center, will
be stripped of all the superseded certificates of label approval and related
applications (covering distilled spirits products) in accordance with prescribed records retention schedules, and destroyed.
Certificates of Exemption from Label Approval
At this time, holders of certificates of exemption from label approval
covering labels for distilled spirits and wines will not be requested to refile.
At such time as the forms of certificate of exemption are redesigned for microfilming, this will be considered.
Outstanding Certificates of Label Approval for Wines and Malt Beverages will
not be Disturbed
As indicated above, while all new applications for label approval submitted on and after July 1, 1968, will be submitted on the 1968 revision of
Form 1649 (all prior revisions of the blank forms on hand should be destroyed),
holders of these certificates will not be asked to refile applications with
respect to previously approved labels at this time. They will be advised
(in a later circular) when they should do so.
Inquiries with respect to the new procedure outlined in this circular
should be addressed to the Director, Alcohol and Tobacco Tax Division, Internal
Revenue Service, Washington, D. C., 20224, Attention: CP:AT:B.
Harold A. Serr
Director, Alcohol and Tobacco Tax Division