Many of you may
already be aware of a recent TTB circular regarding liberalization of label
approval guidelines. However, based on conversations with TTB staff and
member wineries, we believe this TTB circular is important enough, and was
missed by enough people, to be worth re-visiting. It’s not every day that
a government agency takes action to significantly reduce the reach of regulatory
requirements and this effort is both commendable and worth highlighting.
Here are just a few
of many changes to labels that now are allowed without submittal of a new
Certificate of Label Approval (COLA) application:
1)
Changing
the alcohol content across the 14% alcohol tax class threshold (particularly
important for those of us who haven’t yet labeled our reds from the cool, low
alcohol 2011 vintage)
2)
Changing
font styles, background colors, label shape, and label media (for example from
adhesive backed to screen printed on the bottle)
3)
Deleting
any non-mandatory information.
4)
Adding,
changing or deleting web site addresses, UPC symbols or QR codes (Note: Please read
our upcoming blog posting on TTB advertising requirements as regards QR codes
and website references)
For a quick overview,
this link: http://www.ttb.gov/labeling/allowable_revisions.shtml#completeList
has a nice graphic
showing some changes to sample labels that are now allowable. There is
also a concise table that will further clarify label requirements.
The full text of TTB
circular 2012-2, together with its embedded links can be found at this
link: http://www.ttb.gov/labeling/ttb-g2012-2-updated-cola-form-allowable-revisions.pdf
This is good news! We urge all of you to read the full TTB industry circular or, at the very least, to take five minutes to read the overview of changes at the first link above. The first link has a printer friendly version available and is concise enough to use as a quick reference guide.
These changes are material,
substantial, and positive, and not only increase stylistic flexibility for
wineries but will also significantly reduce the need to re-submit COLA
applications for existing wines.
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