What Should I Know About Certificate of Label Approvals (COLAs)?

Beverage alcohol suppliers and producers selling in the United States typically must obtain Certificate of Label Approvals (COLAs) from the Alcohol and Tobacco Tax and Trade Bureau (TTB) before product distribution. This ensures that suppliers and producers are compliant with federal regulations regarding the design of their alcohol labels. (Additionally, most states have their own registration requirements that must be met before products can be sold.)

But what do suppliers and producers need to know about COLAs? How can you ensure that your product can compliantly make it to market?

Here are key highlights about COLAs and what it takes to get them approved.

Know what’s required

• An item’s brand name, area of production, type of product and volume of the container’s content must be included.
• The Government Warning must be included and in a specific format.
• The regulations can vary for beer, wine and distilled spirits.

Know what’s prohibited

• Health claims or disparaging remarks about competitors’ products are not allowed.
• Neither are references to other intoxicating substances nor claims about the “strength” of the product’s alcohol content.

Register with the TTB

• The TTB reviews labels to ensure they incorporate all necessary information and exclude prohibited messaging.
• If labels are not approved, they are sent back to be fixed.

Check for new and revised labels

• If a supplier updates a label, that may require applying for a new COLA. The TTB has allowable revisions that can be done without getting a new COLA, saving time and effort.
• Old labels may need to be surrendered and not used again in commerce.

Understand exceptions and exemptions

• There are some exclusions to the COLA process, such as wines with an ABV less than 7% and malt beverages that do not meet the FAA Act definition of beer (containing water, malted grains and hops).
• Certain products are subject to the FAA Act but are exempt in certain circumstances from needing a COLA, such as beer that is only sold in the state where it is produced.