Associations and state partners: Please feel free to share the article below in your newsletters, websites, and communications to educate your industry members on federal label approval.  

Have you ever wondered when, and how, to get label approval from the Alcohol and Tobacco Tax and Trade Bureau (TTB)? These quick tips will help you to get approval and stay compliant with federal labeling requirements! 

When is TTB label approval required? 

Obtaining a certificate of label approval (COLA) from TTB is required for products that fall under the Federal Alcohol Administration Act (FAA Act). The FAA Act applies to the following products when they are sold, shipped, or otherwise introduced in interstate commerce:  

• Distilled spirits 

• Wines that contain 7% to 24% alcohol by volume 

• Malt beverages (for example, beers that contain both malted barley, and hops)  

Distilled spirits and wines (with an alcohol content from 7% to 24%) that are sold only within the state where they are bottled may qualify for a certificate of exemption instead of a COLA.  Malt beverages that are only sold intrastate do not need a COLA or a certificate of exemption. 

For domestic products, a COLA (or certificate of exemption) must be obtained by the bottler prior to bottling. This applies even when contracting with another entity to produce products for you: The bottler gets the COLA.  For imported products, the importer must obtain the COLA prior to removal from Customs custody.  

Wines containing less than 7% alcohol by volume and beers that do not contain both malted barley and hops do not need a COLA (or certificate of exemption) from TTB, but may still be subject to labeling requirements of the Internal Revenue Code and Alcoholic Beverage Labeling Act administered by TTB and the Federal Food, Drug, and Cosmetic Act administered by the Food and Drug Administration. 

When you want to make changes to an approved label, consult the complete list of allowable revisions—you may not need to send us the revised labels at all. 

What are the requirements for label approval? 

The requirements of the FAA Act and its implementing regulations vary for distilled spirits, wines, and malt beverages, but all labels must be truthful, not misleading, and include all mandatory information. Applications that do not meet these requirements will be returned for correction.