TTB Approves COLA Changes for Altering Approved Labels

In an update to Form 5100.31, the TTB has created a win-win for label approval and label modification.  Offering updated guidance for changing previously approved labels, the new form allows for a series of new alterations that are worth reading:




/* Style Definitions */
{mso-style-name:”Table Normal”;
mso-padding-alt:0in 5.4pt 0in 5.4pt;

Once a label receives TTB approval, you can make certain changes
to that label without obtaining a COLA from TTB. Any revision(s) you make
to your approved label(s) must be in compliance with the applicable regulations
in 27 CFR parts 4,
 5, 7 and
and any other applicable provision of law or regulation, including, but not
limited to, the conditions described in the “Comments” section of the
chart below.


1. Delete any non-mandatory label information, including text,
illustrations, graphics, etc. 

2. Reposition any label information, including text,
illustrations, graphics, etc.

3. Change the color(s) (background and text), shape and
proportionate size of labels. Change the type size and font, and make appropriate
changes to the spelling (including punctuation marks and abbreviations) of
words, in compliance with the regulations. Change from an adhesive label to one
where label information is etched, painted or printed directly on the container
and vice versa.

4. Change the stated percentages for blends of grape varietals
and appellations of origin for wine labels.

5. Add, change or delete a vintage date for wine labels.

6. Change the optional “produced” or “made” by statements on
wine labels to “blended”, “vinted”, “cellared” or “prepared” by statements.

7. Add, change or delete the stated amount of acid and/or the pH
level for wine labels.

8. Change the stated amounts of sugar at harvest and/or residual
sugar for wine labels.

9. Add or delete bonded winery or taxpaid wine bottling house
number for wine labels.

10. Change the net contents statement.

11. Change the mandatory statement of alcohol content, where
such change is not inconsistent with the labeled class and type designation, or
with any other labeling statements.

12. Add, delete, or change an optional statement of alcohol
content for malt beverage labels.

13. Change the statement of percentage of neutral spirits and
the name of the commodity from which a distilled spirit is produced.

14. Change the mandatory age statement, or delete or change an
optional age statement for distilled spirits labels.

15. Delete or change an optional age statement, including a
barrel aging statement, for wine and malt beverage labels.

16. Add, delete, or change statements or information in order to
comply with the requirements of the State in which the malt beverage is to be

17. Change the numerical values for calories, carbohydrates,
protein, and fat contained in a statement of average analysis.

18. Add, delete, or change stated bottling date, production date
(day,month,and/or year) or freshness information including bottling, production
or expiration dates or codes.

19. Change the name or trade name to reflect a different name
already approved for use by the responsible bonded wine cellar, taxpaid wine
bottling house, distilled spirits plant, brewery, or importer. Change the
address where it is within the same State.

20. Add, delete, or change the name and/or address of the
foreign producer, bottler, or shipper.

21. Add, delete, or change the name, address, and/or trademark
of the wholesaler, retailer, or persons for whom the product is imported or

22. Add, delete, or change bottle deposit information.

Add, delete, or change UPC barcodes and/or 2D mobile barcodes, e.g., QR codes
or Microsoft Tags

Ashley Brandt

Hi there! I’m happy you’re here. My name is Ashley Brandt and I’m an attorney in Chicago representing clients in the Food and Beverage, Advertising, Media, and Real Estate industries. A while back I kept getting calls and questions from industry professionals and attorneys looking for advice and information on a fun and unique area of law that I’m lucky enough to practice in. These calls represented a serious lack of, and need for, some answers, news, and information on the legal aspects of marketing and media. I've got this deep seeded belief that information should be readily available and that the greatest benefit from the information age is open access to knowledge... so ... this blog seemed like the best way to accomplish that. I enjoy being an attorney and it’s given me some amazing opportunities, wonderful experiences, and an appreciation and love for this work. I live in Chicago and work at an exceptional law firm, Goldstein & McClintock, with some truly brilliant people. Feel free to contact me at any time with any issues, comments, concerns… frankly, after reading this far, I hope you take the time to at least let me know what you think about the blog and how I can make it a better resource.

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