Beer Label Fundamentals

Alex Koral
October 27, 2022

While beer brand labels are a great way to set your product apart with clever marketing and design, there are rules brewers must follow while designing them. Beer labels, whether on a bottle, can or keg, have lots of information that is highly regulated, both at the federal level and by individual states. We’ve compiled the basic information required by both the federal and state levels to help maintain compliance as you begin the label design process.

Federal regulations

Beer labels are regulated by federal law under both the Internal Revenue Code and the Federal Alcohol Administration Act. These rules on what must be included and what is prohibited from being on a label are in turn managed by the Alcohol and Tobacco Tax and Trade Bureau (TTB). By law, beer labels must contain the following information:

  • The name the product is being marketed under.
  • The name and address of the producer or importer.
  • Information regarding the class or type of alcohol.
  • The size of the container and its alcohol content.
  • A government warning statement outlining health risks associated with consuming.

All of this information must be formatted to match the TTB’s standards.

What information can a label not provide? There are a few hard-and-fast rules. Beer labels are prohibited from containing the following content:

  • False statements that could mislead consumers.
  • Disparaging remarks or images that demean a competitor.
  • Geographic terms that give a false impression of the geographic source of the product.
  • Government iconography that gives the impression that the product is sponsored by any governmental body.
  • Untrue health claims and false endorsements.

COLAs

Certificate of Label Approvals (COLAs) ensure that suppliers and producers comply with federal regulations when marketing and designing alcohol labels. Under federal law, most alcoholic products  must first be registered with the TTB and receive a COLA before they can be sold. For beer products, though, a COLA is only required when they are sold in interstate commerce.

Obtaining a COLA is a relatively straightforward process. Perform a self-review of your label to ensure it meets all the TTB’s Beverage Alcohol Manual (BAM) guidelines, then submit your COLA through COLAs Online and wait up to two weeks for a response. It’s important to note that your COLA will not be “rejected” per se, but if it’s not approved immediately, it will be sent back to give you the opportunity to correct any errors before reapplying. The top reasons for a returned COLA are missing or improperly formatted required information, discrepancies between license information listed on the label and what is in the TTB’s records, and missing formulas.

If at any point you make changes to your label, you may be required to apply for a new COLA. The TTB has allowable revisions that can be completed without getting a new COLA, so be sure to double check before re-applying to save you time and effort.

State regulations

In addition to the federal label requirements, most states have their own brand label registrations. State brand label registrations typically require providing a COLA and paying a fee. Even if you don’t sell interstate, your beer must meet the requirements of the Internal Revenue Code. States require registrations for several reasons, including to better monitor franchise rules, to identify what’s on store shelves and to verify proper labelling.

Taking the time to understand federal and state-level beer labeling requirements is critical to compliance. Planning ahead and strictly adhering to TTB guidelines is the best way to start your beer labeling process.

Take Action

Ready to start the process for certificate of label approvals (COLAs)? Find out how Sovos ShipCompliant can help.

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Author

Alex Koral

Alex Koral is Senior Regulatory Counsel for Sovos ShipCompliant in the company’s Boulder, Colorado office. He actively researches beverage alcohol regulations and market developments to inform development of Sovos’ ShipCompliant product and help educate the industry on compliance issues. Alex has been in the beverage alcohol arena since 2015, after receiving his J.D. from the University of Colorado Law School.
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