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Industry Circular

Number: 85-6

Date: July 4, 1985

Department of the Treasury

Bureau of Alcohol, Tobacco, and Firearms

Washington, D.C. 20226


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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 1649 (5100.14).

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 of wines.

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.

Effective Dates

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 20226.

Stephen Higgins


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