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Label Compliance Guide for Alcoholic Beverages in the US – Part 1


October 4, 2018

This blog series will demystify the labeling and advertising requirements for Wine, Distilled Spirits and Malt Beverages in the United States (all states, the District of Columbia, and the Commonwealth of Puerto Rico).

This post will introduce the reader to the parts in the applicable regulation, the enforcing authority and the procedure for obtaining label approval for alcoholic beverages.

According to the latest electronic Code of Federal Regulations (e-CFR), the following are the pertinent parts:

  • 27 CFR Part 13, Labeling Proceedings – Governs the procedure and practice in connection with the issuance, denial, and revocation of certificates of label approval, certificates of exemption from label approval, and distinctive liquor bottle approvals under 27 U.S.C. 205(e) and 26 U.S.C. 5301.
  • 27 CFR Part 4, Labeling and Advertising of Wine – In addition to Scope and Definition, this regulation covers:
    • Standards of Identity for Wine
    • Labeling Requirements for Wine
    • Requirements for Withdrawal of Wine from Customs Custody
    • Requirements for Approval of Labels of Wine Domestically Bottled or Packed
    • Advertising of Wine
    • Standard of Fill for Wine
    • General Provisions
    • American Grape Variety Names
    • Use of the term “Organic”
  • 27 CFR Part 5, Labeling and Advertising of Distilled Spirits – This regulation covers:
    • Standards of Identity for Distilled Spirits
      • Formulas
    • Labeling Requirements for Distilled Spirits
    • Standards of Fill for Bottled Distilled Spirits
    • Requirements for Withdrawal from Customs Custody of Bottled Imported Distilled Spirits
    • Requirements for Approval of Labels of Domestically Bottled Distilled Spirits
    • Advertising of Distilled Spirits
    • Use of the term “Organic”
  • 27 CFR Part 7, Labeling and Advertising of Malt Beverages – This regulation covers:
    • Labeling Requirements for Malt Beverages
    • Requirements for Withdrawal of Imported Malt Beverages from Customs Custody
    • Requirements for Approval of Labels of Malt Beverages Domestically Bottled or Packed
    • Advertising of Malt Beverages
    • General Provisions
    • Interim Regulations for Alcoholic Content Statements
    • Use of the term “Organic”
  • 27 CFR Part 16, Alcoholic Beverage Health Warning Statement – The regulations in this part relate to a health warning statement on labels of containers of alcoholic beverages.

If you are producing or importing alcoholic beverages into the United States, Certificate of Label Approval (COLA), issued by The Alcohol and Tobacco Tax and Trade Bureau (TTB), is mandatory before product launch. Alcohol Labeling and Formulation Division (ALFD) within the TTB issues COLA or grants exemptions.

COLA “authorizes the bottling or packing of wine, distilled spirits, or malt beverages, or the removal of bottled wine, distilled spirits, or malt beverages from customs custody for introduction into commerce, as long as the project bears labels identical to the labels affixed to the face of the certificate, or labels with changes authorized by the certificate.”

The typical processing time for label applications are as follows:

Current Label Processing Times: As of: 10 / 3 / 2018    5:01 AM
2018 COLA applications received year-to-date: 140,449 (as of 9/6/18)
Application TypeAverage Label Processing Time
(Calendar Days):
Today We are Processing New* Applications Received On:
Distilled Spirits Labels10 days10 / 1 / 2018
Malt Beverages Labels9 days9 / 25 / 2018
Wine Labels3 days10 / 1 / 2018

Courtesy: https://www.ttb.gov/labeling/processing-times.shtml

The next post in this series will cover provisions under Labeling Proceedings as well as Labeling and Advertising of Wine.

Courtesy: Aravind Ravi, Technical Documentation Manager at ManageArtworks.

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