Expansion of Allowable Label Revisions by TTB Helps Industry

Last week TTB expanded the list of Allowable Revisions to Approved Alcohol Beverage Labels within the Industry Circular 2014-02. These minor changes come after a major effort last year to reduce the number of new label submissions from domestic suppliers. You can read more about the first change in this blog post. Previously approved labels with new changes that fall within the list of allowable revisions, both existing and the below additions, do not need to be approved again. This topic will also be discussed at the 1st Annual ShipCompliant Wholesale Gathering in White Plains, NY on October 16th.

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29. Delete or change promotional sponsorship-themed graphics, logos, artwork, dates, event locations and/or other sponsorship-related information (e.g., sports leagues, team organizations, annual sporting events, and annual or semi-annual festivals). If authorization by a third party was required for use of such promotional sponsorship-themed information on a label when first approved, it is the responsibility of the industry member to have any necessary documentation of authorization to cover the revisions to the approved label(s).
30. Add, delete, or change a label or sticker that provides information about a rating or recognition provided by an organization (e.g., “Recognized as one of the top values in vodka by x Magazine” or “Rated as the best 2012 wine by x Association”), as long as the rating or recognition reflects simply the opinion of the organization and does not make a specific substantive claim about the product or its competitors. These statements or graphics must not conflict with or qualify any mandatory information and must comply with all applicable laws and regulations.  Substantive claims about the product or its competitors are not covered by this exemption.
31. Delete all organic references from the label. If you choose to delete one organic claim on a label on which you have received approval to make organic claims, then all organic claims, references, and certification statements must be deleted on the revised label.  The deletion of individual references or certification statements is not permitted without a new COLA.
32. Change an approved sulfite statement to any of these options: “Contains Sulfites,” “Contains (a) Sulfiting Agent(s),” “Contains [name of specific sulfating agent],”“Contains Naturally Occurring and Added Sulfites,” or “Contains Naturally Occurring Sulfites.”“Sulphites” may be used in lieu of “Sulfites.” A sulfite statement is required when sulfur dioxide or a sulfiting agent is detected at a level of 10 or more parts per million, measured as total sulfur dioxide. The statement used must accurately reflect all of the sulfur dioxide or sulfiting agent(s) present in the alcohol beverage. For wine:  Any other variation of the statement or removal of the statement requires a lab analysis. For sulfite waivers, the proprietor must have proof of sample analysis from a TTB-certified laboratory or from the TTB Compliance Laboratory.
33. Add, delete, or change information about the number of bottles that were “made,” “produced,” “brewed,” or “distilled” in a batch; respectively. Example:  “100 bottles produced.”
34. Add certain instructional statements to the label(s) about how best to consume or serve the product.  Only the statements listed in the comments section may be added. Only the following statements are approved to be added to a label:“Refrigerate After Opening”“Do Not Store In Direct Sunlight”,“Best If Frozen For ___ to ___ Hours”, “Shake Well”, “Pour Over Ice”, “Best When Chilled”, “Best Served Chilled”, “Serve Chilled”, “Serve at Room Temperature”

Wine: Managing sulfite and organic statements are much less stringent. (8,027 approved wine labels in September 2014)

Malt: Adding or removing those treasured “Beer Festival” recognitions on labels will no longer require a new label. (708 approved malt labels in September 2014)

Spirits: Small batch whiskey information can be more dynamic on versions of the label. And, the growing interest in organic spirits will help TTB and suppliers be more efficient. (1,286 approved spirits labels in September 2014)

For more information, you may view the complete list of allowable revisions here. Thus far, TTB has approved 90,749 new COLAs this year, with 10,267 in September alone. Keep an eye on newly approved COLAs by clicking here.

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