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This article is for informational purposes only and does not constitute legal advice. Laws are subject to change, and interpretations may vary by jurisdiction and circumstance. The specific requirements related to your products may not be addressed in this article. Please consult your legal counsel prior to taking any action based on anything contained in this article
No Label Left Behind: A Primer on Alcohol Labeling and COLAs
[Griffo tapped our long-time legal partner, Lucas Noble from Crafted Legal , to share these helpful insights to navigate the world of TTB label approval more easily.]
A COLA, or Certificate of Label Approval, is an approval from the Alcohol Labeling and Formulation Division (ALFD) at the Alcohol and Tobacco Tax and Trade Bureau (TTB) (more acronyms). It ensures alcohol labels conform to federal standards that protect consumers and level the playing field among competitors.
Many people know what COLA stands for, but understanding the approval process itself is much trickier. Each commodity (beer, wine, and spirits) has its own regulatory framework, with distinct labeling requirements for different classes within each of those categories. This guide provides a primer on the who, what, where, why, and how of COLA filings, plus practical tips to improve your chances of approval on the first submission.
Understanding COLAs Online
COLAs Online, the portal through which alcohol beverage labels are submitted, can be accessed by production permitholders (distilleries, wineries, breweries). If you own a private beverage brand and are working with a copacker to produce your products, your copacker will submit your label for approval under its own permit.
Because of this, failing to align on label requirements with your co-packer can result in delays, rejections, or mislabeled inventory. Work closely with your co-packer to understand their expectations and approval timeline for your product labels.
Mandatory Label Information
Required information on beverage labels vary across beer, wine and spirits, but there is certain information that must be included on all labels:
Brand Name: The name under which the product is marketed must appear on the brand label.
Class and Type Designation: The specific identity of the beverage must appear on the brand label. Requirements vary by commodity:
Spirits: Type designation (e.g., "Whiskey," "Vodka," "Rum," "Tequila," "Gin")
Wine: Type designation (e.g., "Table Wine," "Aperitif Wine," “Vermouth”)
Malt Beverages: Class/type (e.g., "Beer," "Ale," "Stout”)
*Helpful tip: Specialty products not fitting traditional classes must include a statement of composition (e.g., "Vodka with natural flavors”; "Whiskey infused with local botanicals")
Alcohol Content: Requirements vary by commodity and state:
Spirits: Required on the brand label, stated as percentage ABV (e.g. 40% Alc. by Vol.)
Wine: Required on any label
Government / Health Warning Statement: Required to appear on a brand, back or side label, and must be written exactly as follows:
GOVERNMENT WARNING: (1) According to the Surgeon General, women should not drink alcoholic beverages during pregnancy because of the risk of birth defects. (2) Consumption of alcoholic beverages impairs your ability to drive a car or operate machinery, and may cause health problems. |
Helpful Tip: The words “GOVERNMENT WARNING” must appear in capital letters and in bold type; the remainder of the statement may not appear in bold type.
Name and Address Statement: The name (or trade name) and address (city and state) as listed on the basic permit, i.e. Produced by Crafted Legal Libations, San Luis Obispo, CA.
Ingredient Disclosures: Certain ingredients require disclosure on labels, e.g. certified or artificial colors, wood chips, sulfites. Be sure to review TTB’s distilled spirits and wine labeling checklists for more information.
Understanding these requirements is the foundation, and no label will be approved without these necessary components. Now, I’ll provide some reminders to keep top of mind as you begin designing your labels or start preparing for submission.
Practical Tips for Success
Successfully obtaining a COLA requires more than just submitting a label. Planning ahead, understanding the approval timeline, and knowing common pitfalls can significantly improve your chances of a smooth approval process. Here are key strategies to help ensure your COLA submission moves forward without unnecessary delays or rejections.
Start the COLA process well before your production launch date
Your product labels must match the label that is approved in the COLA
Know that any label changes require a new COLA submission; unless the change is an allowable revision.
Review state-specific labeling requirements, which sometimes are more stringent that TTB requirements
Consider consulting with label compliance specialists if unfamiliar with requirements
Budget time for potential revision rounds; many approvals require corrections
Keep digital and printed copies of all approved COLAs on file
Remember that COLA approval does not grant trademark protection
Work with your copacker to understand their COLA process, fees, and timelines
Common COLA Rejection Reasons
Many COLA submissions are approved with minor revision, but knowing the most frequent reasons for rejection can help you avoid unnecessary setbacks. The list below includes some of the most common issues I see and which are repeatedly cited in TTB correspondence. By addressing these common problems before you submit, you can decrease the chance that your label requires corrections, and hopefully streamline your path to approval.
Incomplete or inaccurate ingredient information
Incorrect or missing Health Warning Statement
Font sizes smaller than minimum requirements
Missing origin or appellation statements (wine)
Making unsupported health or nutritional claims (use of the words “pure” or “holistic” to describe product)
Submitting labels before obtaining formula approval (for certain beverage classes/types)
Inconsistent information between multiple label panels
Obtaining COLA approval might seem daunting, but the process becomes manageable when you understand the requirements and plan accordingly. The more time you have, the less stress you’ll have during the submission process. And effort spent getting labels right before submission can save significant time and resources.
We hope that this guide has been a helpful primer on COLAs. Start early, stay organized, and your path to approval will be straightforward!