Alcohol labels: TTB and COLA requirements explained

Alcohol labels are among the most regulated labels a designer will work on. In the United States, most wine, beer and spirits labels must be approved by a federal agency before the product can be sold across state lines, and state rules can add more. This guide explains how the system works, what usually has to appear on an alcohol label and how to plan your design so approval goes smoothly.

It is a general guide, not legal advice. Requirements depend on the product type, alcohol content, container size and where it is sold. The Alcohol and Tobacco Tax and Trade Bureau (TTB) publishes detailed guidance, linked below, and your adviser or importer should confirm the final text.

Who regulates alcohol labels in the US

The TTB regulates the labelling of most alcoholic beverages under the Federal Alcohol Administration Act. Its regulations in 27 CFR cover:

• wine (generally 7% alcohol by volume and above)
• distilled spirits
• malt beverages, which include most beers made with malted barley and hops

Some products fall outside the TTB's labelling rules and are regulated by the FDA instead, for example many wines under 7% alcohol by volume and some beers not made from malted barley and hops. These must follow FDA food labelling rules, including ingredient lists and, in some cases, nutrition labelling. Check which agency applies before you design.

States also regulate alcohol. Many require their own label registration or approval, and some have extra rules on deposits, recycling marks or warnings.

What a COLA is

A Certificate of Label Approval, or COLA, is the TTB's approval of a label. For most products under the TTB's labelling rules, you need a COLA before the product is bottled or removed from a bonded facility for sale, or before an imported product is released from customs.

Applications are usually made through COLAs Online. The permittee, such as the winery, brewery, distiller or importer, submits images of every label that will appear on the container, along with information about the product. The TTB reviews the label against its rules and either approves it, asks for corrections or rejects it.

Some products also need a formula approval before the label can be approved, for example certain flavoured malt beverages and spirits with added ingredients. Formula approval can take longer than label approval, so plan for it early.

Mandatory information on TTB-regulated labels

The exact list depends on the product, but most TTB-regulated labels need some or all of the following:

• Brand name. The name under which the product is sold.
• Class and type designation. For example "Bourbon Whisky", "Red Wine" or "India Pale Ale", using the standards of identity in the regulations.
• Alcohol content. Mandatory for distilled spirits and wine above 14% alcohol by volume, and for malt beverages in some circumstances, with defined formats and tolerances.
• Net contents. The volume in the container, using approved standards of fill for wine and spirits.
• Name and address of the bottler, packer or importer, with the correct phrasing such as "Bottled by" or "Imported by".
• Country of origin for imported products.
• Health warning statement. Required on all alcoholic beverages containing 0.5% or more alcohol by volume sold in the US.
• Declarations of certain ingredients, such as sulfites in wine, and some colours and sweeteners.

Some of these items must appear together in the same field of vision, and some must appear on a specific label, such as the brand label. The TTB's guidance for each product type explains which.

The government health warning

The health warning statement is set by law and must be used exactly as written. It begins with "GOVERNMENT WARNING:" in capital letters and bold type, followed by two numbered statements about pregnancy and about driving and health. The regulation in 27 CFR Part 16 sets:

• the exact wording
• that "GOVERNMENT WARNING" must be in capitals and bold, while the rest must not be bold
• a minimum type size based on the container size
• a limit on characters per inch
• that it must appear on a contrasting background and be readily legible

Designers often run into trouble with the character density rule and minimum size on small containers. Plan the space before the rest of the back label.

Type size and placement

TTB rules set minimum type sizes for mandatory information, usually based on container size. For example, larger containers require larger minimum type for certain statements. There are also rules about where information can appear: some items must be on the brand label, some can appear on any label, and some must be in the same field of vision.

Because these rules are product-specific, we recommend working from the TTB's guidance for your product type and building a checklist of every mandatory item, its required position and its minimum size before design begins.

Planning an alcohol label

Start with the mandatory text

Gather the brand name, class and type, alcohol content, net contents, bottler or importer statement, country of origin, health warning and any declarations. Have your adviser or importer confirm them for each market.

Map it to the bottle

Work from the bottle's dimensions or the bottle itself. Decide which items go on the front label, back label, neck label or capsule. Check minimum type sizes against the container size.

Then design

With the mandatory content in place, the brand can take the space that remains. Heritage spirits might use fine engraving and foil; a craft beer might use bold illustration. Because the required information is already planned, you will not have to shrink or move it later.

Leave time for approval

COLA review times vary. If the TTB asks for changes, you will need revised files quickly. Factor approval time into your launch plan, and do not print labels in volume until approval is granted.

Selling outside the US

Other markets have their own rules. The UK and EU require alcohol content, allergen information and, in many cases, nutrition or ingredient information for wine and other drinks, and some countries require specific health warnings. A label designed for the US will usually need changes for export. If you plan to sell in several markets, design a flexible back label that can be swapped by market.

Common reasons labels are sent back

Many COLA corrections come from a handful of recurring issues. Checking for them before submission saves time:

• Class and type does not match the product. The designation must follow the standards of identity. A "whiskey" that does not meet the definition for that class, or a fanciful name used where a class designation is required, will be questioned.
• Health warning formatting. "GOVERNMENT WARNING" not in capitals and bold, the rest of the statement in bold, the text squeezed beyond the character limit, or type below the minimum size for the container.
• Alcohol content format. The statement does not use an accepted format, or falls outside the permitted tolerance for the product type.
• Net contents. The volume is not an authorised standard of fill for wine or spirits, or is missing from the label.
• Bottler or importer statement. The wording does not match the permit, or the address is incomplete.
• Same field of vision. Items that must appear together, such as brand name, class and type and alcohol content for spirits, are split across labels.
• Misleading statements. Health-related statements, references to other products, or images that could mislead about origin, age or composition.
• Missing declarations. Sulfites in wine, certain colours such as FD&C Yellow No. 5, or other ingredients that must be disclosed.

A simple way to catch these is a one-page label checklist for each product type, built from the TTB's guidance, that your designer and your adviser both sign off before submission.

Changing an approved label

Not every change to an approved label needs a new COLA. The TTB allows certain changes, such as some changes to colour, background, size or the position of certain statements, without a new approval, and publishes the list of allowable revisions. Changes to mandatory information, the brand name or the class and type usually require a new application. When you plan a redesign or seasonal edition, check which changes are allowed before you print.

How we help

We design labels and gift boxes for wine, beer and spirits brands and make rigid presentation boxes in our own factory. We lay out the mandatory text you supply with the TTB's format and type size rules in mind, and deliver clean files for your COLA submission and your label printer. We do not submit applications or check compliance; final review stays with you, your importer and your adviser.

See our liquor label design and beverage packaging design services, or get a free quote for your labels and gift boxes.

Official sources

• TTB: Labeling
• TTB: COLAs Online
• 27 CFR Chapter I, Subchapter A: Alcohol (eCFR)
• 27 CFR Part 16: Alcoholic beverage health warning statement (eCFR)

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Questions

What is a COLA?

A Certificate of Label Approval issued by the TTB. Most wine, distilled spirits and malt beverages need one before they are bottled or imported for sale in the US.

Is the government warning required on every alcohol label?

The health warning statement is required on alcoholic beverages containing 0.5% or more alcohol by volume sold in the US, with rules on wording and type size.

Do state rules also apply?

Yes. States can have their own label registration and requirements. Check with your distributor or adviser.

Can a designer submit my COLA?

The application is usually made by the permittee or importer. A designer supplies accurate label files for it.