On Monday, September 29 2014, the TTB issued Industry Circular 2014-2. The Circular expands the list of allowable revisions to approved alcohol beverage labels effective on the date of the circular. These changes will be added to the COLA form when it is next revised.
Industry members may make certain changes to previously approved alcohol beverage labels without applying for a new COLA. There are currently 28 allowable revisions which may be found on the COLA form. Furthermore, TTB has announced in various rulings and guidance documents that specific changes to labels may be made without resubmitting labels for approval. See Industry Circular 2014-1.
Industry Circular 2014-2 permits the following changes to already-approved malt beverage, wine and distilled spirits labels without the need for a new certificate of label approval (COLA):
- The deletion or revision of sponsorship themed graphics, logos, artwork, and/or sponsorship information.
- The addition, deletion, or revision of awards, ratings, or recognition, such as “Rated a Top Value Wine of 2014 by xyz Association.”
- The deletion of organic claims provided that all organic claims are removed from the label. A new COLA would be required to delete individual “organic” references while maintaining other “organic” references.
- The revision of an approved sulfite statement according to the formats prescribed by the Industry Circulars. The options are: “Contains Sulfites,” “Contains (a) Sulfiting Agent(s),” “Contains [the name of specific sulfating agent],” “Contains Naturally Occurring and Added Sulfites” or “Contains Naturally Occurring Sulfites”.
- The addition, deletion, or revision of information regarding the number of bottles made, produced, distilled, or brewed in a batch.
- The addition of certain instruction statements about how best to consume or serve a product. Only the following statements may be added: “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”, or “Serve at Room Temperature”.
Please see the circular for additional information.