Allowable Changes to Approved Labels

Approved Brand Label

Approved Brand Label With Allowable Changes
(No Need To Obtain COLA)

Approved Back Label

Approved Back Label With Allowable Changes
(No Need To Obtain COLA)

YOU MAY...

REVISION APPLIES TO

COMMENTS

WINE

DISTILED SPIRITS

MALT BEVERAGE

1. Delete any non-mandatory label information, including text, illustrations, graphics, etc.

YES

YES

YES

2. Reposition any label information, including text, illustrations, graphics, etc.

YES

YES

YES

The repositioning must comply with any placement requirements applicable to mandatory information. For example, some types of mandatory information must appear on the brand label or must appear together with other label information.

3. Change the color(s) (background and text), shape and proportionate size of labels. Change the type size and font, and make appropriate changes to the spelling (including punctuation marks and abbreviations) of words, in compliance with the regulations. Change from an adhesive label to one where label information is etched, painted or printed directly on the container and vice versa.

YES

YES

YES

All mandatory information must be readily legible and appear on a contrasting background. If you received approval for a single label then you may not divide the label into multiple labels without reapproval. All changes must comply with applicable regulations, and changes in spelling must not change the meaning of the previously approved information.

4. Change the stated percentages for blends of grape varietals and appellations of origin for wine labels.

YES

N/A

N/A

When used for any of these items, the total percentages for each element must equal 100%. You may not change the name of the stated varietals or appellations without submitting a new application.

5. Add, change or delete a vintage date for wine labels.

YES

N/A

N/A

If the vintage date is deleted, no reference to "Vintage" may be made on any label or other materials (e.g., caps, capsules, corks, etc.) affixed to the bottle. When adding a new vintage date, you must comply with all applicable regulations, including the requirements regarding appellations of origin.

6. Change the optional "produced" or "made" by statements on wine labels to "blended", "vinted", "cellared" or "prepared" by statements.

YES

N/A

N/A

7. Add, change or delete the stated amount of acid and/or the pH level for wine labels.

YES

N/A

N/A

8. Change the stated amounts of sugar at harvest and/or residual sugar for wine labels.

YES

N/A

N/A

See ATF Ruling 82-4 for policy regarding use of sugar content statements and when such statements are required.

9. Add or delete bonded winery or taxpaid wine bottling house number for wine labels.

YES

N/A

N/A

If used, a bonded winery number must appear in direct conjunction with the bottler's name and address.

10. Change the net contents statement.

YES

YES

YES

Revisions must comply with all applicable regulations governing net content statements and standards of fill. Please ensure that all applicable type size requirements are met for each container size.

11. Change the mandatory statement of alcohol content, where such change is not inconsistent with the labeled class and type designation, or with any other labeling statements.

YES

YES

YES
(Flavored
Malt Beverages Only)

The change must not result in a change to the labeled class or type designation of the product. For example, a label bearing a "table wine" designation may not be changed to state an alcohol content above 14 percent alcohol by volume, and a label bearing a "rum" designation may not be changed to state an alcohol content statement of less than 40 percent alcohol by volume. The change may not be inconsistent with any other mandatory or optional labeling statements.

12. Add, delete, or change an optional statement of alcohol content for malt beverage labels.

N/A

N/A

YES

Malt beverages that contain alcohol derived from added flavors or other added nonbeverage ingredients (other than hops extract) containing alcohol are subject to mandatory alcohol content statement requirements.

13. Change the statement of percentage of neutral spirits and the name of the commodity from which a distilled spirit is produced.

N/A

YES

N/A

These changes must not result in a change to the class or type designation of the distilled spirits product.

14. Change the mandatory age statement, or delete or change an optional age statement for distilled spirits labels.

N/A

YES

N/A

These changes must not result in a change to the class or type designation. See 27 CFR 5.22 and 5.40 for further information about age statements and minimum aging requirements applicable to certain classes and types of spirits.

15. Delete or change an optional age statement, including a barrel aging statement, for wine and malt beverage labels.

YES

N/A

YES

Statements of age on wine labels must comply with 27 CFR 4.39(b).

16. Add, delete, or change statements or information in order to comply with the requirements of the State in which the malt beverage is to be sold.

N/A

N/A

YES

Applies only to malt beverages sold in that particular State.

17. Change the numerical values for calories, carbohydrates, protein, and fat contained in a statement of average analysis.

YES

YES

YES

Changes must be in compliance with TTB Ruling 2004-1.

18. Add, delete, or change stated bottling date, production date (day,month,and/or year) or freshness information including bottling, production or expiration dates or codes.

YES

YES

YES

Bottling dates added to wine labels must comply with 27 CFR 4.39(c).

19. Change the name or trade name to reflect a different name already approved for use by the responsible bonded wine cellar, taxpaid wine bottling house, distilled spirits plant, brewery, or importer. Change the address where it is within the same State.

YES

YES

YES

This means that a bonded wine cellar, taxpaid wine bottling house, distilled spirits plant, brewery or importer may revise the label to include the use of a name or trade name that is already approved for that particular industry member. The name or trade name must appear on the basic permit, brewer’s notice, or other qualifying documents for the company to whom the original certificate was issued. If the name or trade name is also used as the brand name on the label, resulting in a change of brand name, you must submit a new application. The change in address is ONLY allowed for in-state moves or other changes to the COLA holder’s address that have already been reflected on the industry member’s basic permit, brewer’s notice, or other qualifying documents.

20. Add, delete, or change the name and/or address of the foreign producer, bottler, or shipper.

YES

YES

YES

The producer, bottler, or shipper must be located in the same country originally shown.

21. Add, delete, or change the name, address, and/or trademark of the wholesaler, retailer, or persons for whom the product is imported or bottled.

YES

YES

YES

22. Add, delete, or change bottle deposit information.

YES

YES

YES

23. Add, delete, or change UPC barcodes and/or 2D mobile barcodes, e.g., QR codes or Microsoft Tags.

YES

YES

YES

Addition or change of UPC Code must be in compliance with Industry Circular 77-23. Any information retrieved from 2D barcodes must be in compliance with all applicable advertising regulations.

24. Add, delete, or change a Web site address, phone number, fax number, or zip code.

YES

YES

YES

25. Add, delete, or change a lot or batch identification number or other serial numbers.

YES

YES

YES

26. Add, delete, or change trademark, copyright symbols (e.g., TM, ©, ®), kosher symbols, company logos, and/or social media icons.

YES

YES

YES

Symbols, logos and icons may not violate TTB regulations. Advertisements on social media sites must be in compliance with all applicable advertising regulations.

27. Add, delete, or change optional information about awards or medals.

YES

YES

YES

28. Add, delete, or change holiday- and/or seasonal-themed graphics, artwork and/or salutations.

YES

YES

YES

Holiday/seasonal-themed information or graphics must not conflict with or qualify the mandatory information and must comply with all applicable regulations, including the rules governing prohibited practices.