TTB Labeling and Formula Requirements
-COLA (Certificate of label Approval)-It authorizes bottling of packing of malt beverages. The COLA does NOT constitute trademark protection See TTB F 5100.31
COLA is a 2 step process -pre-COLA Evaluation, then COLA submission
To fit an application you need: A Brewers Notice or A Basic Permit (ex: Importers)
COLA Approval: Approx 54 Days
You need a COLA for all bottles, kegs
-Pre-COLA Evolution questions: Doe my product require formal review, or lab analysis?
-How do I determine if my product requires pre-COLA evaluation? If you add an ingredient other then yeast, hops, malts and water, then YES you do. Industry Circular 2007-4
examples of products for that require formula: Ice beer, malt beverage with flavoring. N/A beers need to be submitted to a lab analysis to prove it’s N/A
Gluten labelling statement: tab rolling 2014-2 for substantion requirements applicable to label application that include gluten content statements for malt beverages.
TTB Ruling 2014-4: a list of exempted from the formula requirements made with certain ingredients. TTB also determined that certain processes such as agin beer in barrels..(slide changed).
Exempt ingredients and process determined to be traditional under tab ruling 2015-1
-3 Ways to Submit an application: 1. formulas online 2.Mail form 5100.31 TTB -ALFD 1310 G St. NW Box 12 Washington DC 3. 1-866-927-2533 Option 8
Labeling Mandatory Information: 1. brand name. 2. Name and address. 3. class/type 4. Net contents. 5 government warning. 6.ABV(optional) Alcohol content (for malt beverage containing alcohol derived from added floors or other non beverage ingredients then abv is mandatory) 27 CFR 7.22 2. For more information look at TTB Malt Bev BAM (Beverage Alcohol Manual) 3. Common Mistakes: label and app don’t match, and class/type listed as brand name on application , leaving the class designation off of the label, IPA (the world “ale” must appear), leaving designation off the base beer off the statement of composition (ex: “ale with vanilla extract”) 4. English units of measure (eg: FL. oz, pints, quarts, gallons). May show both metic and English Units. Common mistakes: stating “oz.” instead of “fl. oz” on late, stating “16 fl. oz” instead of “1 pint” (may list both), not converting measurements (22fl oz. vs 1 pint 6 fl. oz), listing only metric units (750ml). lol, what a joke. 5. Alcohol Content: is mandatory for malt bev that contain alcohol from added flavors or other added flavors. Must be listed as “X%abv”. 6. Government warning must be on label “GOVERNMENT WARNING” must appear in capital letters and bold type 7. Geographic Names 27 CFR 7.24
Kegs: are consumer container just like bottles or cans, must meet the labelling requirements, labels bearing mandatory info must be firmly affixed and may include keg caps collars, stickers. Common problems, missing class/type, us of abbreviation of ABV, label that has blank spaces for mandatory info or that has multiple check boxes with nothing checked, government warning not there. Multiple beers are allowed on keg collar as long as all necessary required information is listed on the collar, allowing brewer to check mark which beer is in the keg.
Growlers: TTB Beer FAQ B9. Determined the container type: a growler is a large glass. Check with State Authority (SLA)
Contact info: [email protected] 1-866-927-2533
Known application problems: 1: Certificate of label approval must be checked 2: Make sure brewers permit matches the application 3: You can apply for multiple sizes in cans if the labels are the same. If going from Keg to can the label will be different so you may need 2 different COLA’s. 4: