ATF FORM 1649 (5100.14) -- APPLICATION FOR
AND CERTIFICATION OF LABEL APPROVAL
UNDER FEDERAL ALCOHOL ADMINISTRATION ACT
Proprietors of Distilled Spirits Plants, Bonded Wine
Cellars, Taxpaid Wine Bottling Houses, Brewers, Wholesalers,
Importers and others concerned:
Purpose: The Bureau expands conditions under which
changes may be made to labels without filing new
certificates of label approval on ATF Form 1649 (5100.14)
and other changes in instructions for preparing ATF Form
Background: The reverse of ATF Form 1649 (5100.14)
lists circumstances under which changes may be made to
labels without filing new certificates of label approval.
This circular serves to remind Industry members of these
circumstances and to announce other changes in the label
approval process. The changes will be incorporated into ATF
Form 1649 (5100.14) when it is revised.
Existing changes permitted:
1. In shape or proportionate size of labels.
2. In net content statement.
3. In name and/or address of the foreign producer, bottler
or shipper, if the producer, bottler or shipper is located
in the same country originally shown.
4. In statement of percentage of neutral spirits and name
of commodity from which produced.
5. In proof stated on distilled spirits.
6. In period of age stated.
7. In statement of age and percentage on distilled spirits.
8. In name and registry number of the distiller of spirits
bottled in bond.
9. By adding, deleting or changing on the brand or back
label the name and address or trademark (or both) of the
wholesaler, retailer, or persons for whom imported or
bottled, or by adding another label stating such information
provided that no reference is thereby made to the product or
any of its characteristics.
10. By adding a statement of net contents to the brand,
back or other label corresponding to the required statement
shown elsewhere on the labels or blown into the bottle.
11. In the case of malt beverages, by adding, deleting or
changing a statement of alcoholic content or other wording
in the exact form required by the state in which the
beverage is to be sold.
12. In stated amount of sugar at harvest or resident sugar
13. In the case of wines, a change in the alcoholic content
statement, if within the prescribed limitation for that
class or type of wine and within the same taxable grade.
Additional and amended changes permitted:
1. In name and/or name of responsible winery, DSP, brewery
or importer provided the name/trade name has been added to
Basic Permit or Brewers Notice.
2. In stated vintage date of wine or deletion of vintage
date of wine or deletion of vintage year. NOTE: If vintage
date is deleted no reference to "VINTAGE" may be made on any
label affixed to the bottle. VINTAGE DATES MAY NEVER BE
ADDED, ONLY CHANGED OR DELETED.
3. In stated bottling date.
4. In stated amount of acid or ph level. One or both may be
deleted from label.
5. In adding bonded winery number in direct conjunction
with the bottler name and address.
6. In stated percentages for varietal and/or appellation.
7. In stated caloric content for wine or distilled spirits.
8. In stated average analysis for malt beverages provided
change is in compliance with Industry Circular 80-5.
9. By adding or changing U.P.C. Code as permitted by
Industry Circular 77-23.
Other Changes in Preparing ATF Form 1649 (5100.14):
Currently labels for all domestically bottled products must
be submitted in final form. This restriction will be eased
by permitting legible printers proofs and photocopies of
labels. Photocopies of can flats will also be required to
aid in microfilming of the labels.
Oversized labels must be reduced prior to affixing to ATF
Form 1649 (5100.14), with a notation that the labels have
been reduced. In addition, photocopies of ATF Form 1649
(5100.14), copied front and back with original signatures,
will be permitted.
The changes outlined in this circular shall be effective on
its publication date.
Inquiries: Inquiries concerning this circular should
refer to its number and be addressed to the Associate
Director (Compliance Operations), ATTN: Chief, Industry
Compliance Division, Bureau of Alcohol, Tobacco and
Firearms, 1200 Pennsylvania Avenue, NW , Washington, DC