Changing a label is a standard part of the brand development process. When you decide to update a previously approved label, it is essential that you review the TTB’s list of allowable revisions before you submit a new COLA application. In some instances, your updates may not require you to send in the new label at all. The TTB has made efforts to reduce the number of new label submissions from domestic suppliers, which you can read more about in a previous blog post.
After your label receives its initial approval, there are 34 revisions the TTB allows that do not require you to submit a new COLA. Interpreting these allowable revisions can prove to be tricky, and may even feel like it’s not worth the time. However, these were implemented to reduce submissions and approval times for you and your business. Spending some time understanding these revisions can save you time and money.
Time and time again, we’ve heard from the ShipCompliant Beverage Alcohol Community that the Lighthouse example the TTB provides is confusing. The most important takeaway from this example is that REMOVING graphics and illustrations is allowed but adding is not.
In the example from the TTB shown below, you’ll see that significant changes were made to the label. However, in this instance, a new COLA is not required, as each of the changes made is included in the 34 allowable revisions. We encourage you to review this example to better understand how to take advantage of allowable revisions.
Eliminating new COLA submissions for previously approved labels allows you to get your products to market faster. Understanding the allowable revisions enables you to increase the efficiency of the process, which means more sales for your business.
This topic will also be discussed at the ShipCompliant Wholesale Gathering at DIRECT in Napa, CA on May 29th. Visit our blog later this week for details on the conference or check out our new Beverage Alcohol Community to find answers to your most common beverage alcohol supplier questions.