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Beer Labels

  • Designing a Beer Label
  • Applying for a Beer COLA
  • Pre-COLA Evaluations for Beer

Each container of beer (more generally called a “malt beverage”) must be labeled with a government-approved label before it can be sold. The TTB is the government agency responsible for reviewing and approving alcohol beverage labels, including beer. You must generally obtain a Certificate of Label Approval (“COLA”) for each label and each version of your labels. You can file the application for a beer COLA as soon as you receive a Brewer’s Notice permit. You must submit a sample label with that application. In some cases, you must submit your product formula for TTB evaluation before filing a COLA application.

The following list is not comprehensive, but includes some of the most common malt-beverage label requirements. Depending on the type of beer, location of bottling, and other factors, the required label information may differ from what’s included below.

Containers holding malt beverages must have at least one label called a “brand label.” No other labels are required, but additional labels are permitted. As discussed below, certain information must be displayed on the container’s brand label.

The brand label must include the brand name used to identify and market the malt beverage. Your brand name cannot mislead consumers about the age, identity, origin, or other characteristics of the malt beverage.

Exmaples: Ninkasi; Sierra Nevada

The TTB has divided malt beverages into a number of different classes. The brand label must include your malt beverage’s class designation. For example, stout is a class of malt beverage. To be classified as a stout, your malt beverage must have been fermented at a comparatively high temperature, contain .5% or more alcohol by volume, and possess the characteristics generally attributed to the trade understanding of stout.

For more information on the TTB malt beverage class designations, see Chapter 4 of the Beverage Alcohol Manual

The alcohol content must be stated for any malt beverage that contains alcohol derived from added flavors. For all other malt beverages, the alcohol content may, but is not required to, stated on the label unless omitting it is prohibited by state law. If the alcohol content is stated, it must be expressed in percent by volume.

Example: 5% Alc./Vol.

Each container containing a malt beverage that is .5% or more alcohol by volume must include a health statement that is separated from other information on the bottle through the use of space or on a separate label. The health statement may be on the brand label, back label, or on a separate front, side, or back label. The statement must state 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.” The words “GOVERNMENT WARNING” must appear in all capital letters in bold type. The remainder of the statement may not be in bold type. The statement must appear as a continuous paragraph.

The name and address of the bottler must appear on the brand label. If the product is bottled for distribution by a person other than the brewer, in addition to the name and address of the bottler, the label may also state the name and address of the brewer following a phrase such as “bottled for” or “distributed by.”

Example: Brewed and Bottled by MWS Rose Brewing Co., Boise, Idaho

The net contents of a malt beverage container must be sated in English units of measure (e.g., pints, fluid ounces).

Example: 12 FL. OZ.

The terms draft and draught generally mean that the product has not been pasteurized and that some other method, such as sterile filtration, has been utilized to remove or inhibit bacterial growth. Pasteurized beer may not be described as draft beer. However, it can be described using phrasing such as “draft brewed” or “draft beer flavor” as long as the label also states that the beer has been pasteurized.

A malt beverage label may include a caloric representation such as “lite” or “light,” as long a statement of average analysis appears on the label. The average-analysis statement must be stated per container size if the container is 12 fl. oz. or less. It must also include the amount per serving of calories, carbohydrates, protein, and fat.

Example:

  • Per 12 Fl. Oz Average Analysis:
  • Calories..........100
  • Carbohydrates..........2.7 Grams
  • Protein..........9 grams
  • Fat..........0 grams

A malt beverage may be labeled with a phrase such as “Low Carb” if the product contains no more than 7 grams of carbohydrates per 12-ounce serving. The label must include a statement of average analysis like the caloric-representation analysis sample.

Nearly all beer sold in the United States must be labeled with a government-approved label. To obtain government approval, you must submit an application for a certificate of label approval (“COLA”) to the TTB. You cannot submit the application until you receive a Brewer’s Notice allowing you to manufacture or sell your product. You must also prepare a sample label to submit with the application. The easiest and most efficient way to submit a COLA application is to create an account with COLAs Online which you can access through the TTB website.

To file a COLA application, you must first establish that the person completing the application has the authority to interact with the TTB on your behalf. If the person completing the application was not listed as someone with such authority on your permit application, you must submit additional documentation to the TTB authorizing the person to complete the application. If the person filing the COLA application was listed as having such authority, skip to Section 4 of this article.

The TTB recognizes two types of signing authority.

The first is authority a person has because they are a member of an LLC or officer of a corporation. (Go here for more on selecting the appropriate kind of business entity.) If the person completing the COLA application is a member of your LLC or officer of your corporation, but was not listed as having signing authority when you filed your alcohol permit application, someone else who already has TTB-recognized authority to act on your company’s behalf must execute and file a TTB form called a Signing Authority giving the person the authority to act on your behalf. The TTB Signing Authority form is available on the TTB’s website. This type of form is also appropriate if you wish to have a company employee interact with the TTB.

The second type of singing authority is a Power of Attorney. The Power of Attorney form is the appropriate form to file if the person completing the application is acting on your behalf in a representative capacity, such as the company’s attorney or accountant. The form is also available on the TTB’s website. Again, someone at the company who the TTB has already recognized as having authority to act on the company’s behalf must sign the Power of Attorney.

Once you’ve completed the appropriate form authorizing someone to act on the company’s behalf, you must amend your Brewer’s Notice to include the new authority. The easiest way to amend your application is to log into your TTB Permits Online Account and select the “Create Amendment” option next to your approved application record. You cannot register to use COLAs Online on the company’s behalf until the TTB approves the amendment.

Once you have completed steps 1-3 above, or determined you can skip them, you may register on COLAs Online to file the COLA application. Registration is fairly straightforward. You are required to provide information such as your contact information, permit number, and date of permit issuance. Once you’ve completed each of the required steps, you can submit the registration request. The TTB may take up to 20 days to verify your authorization, but generally it takes much less time.

Once the TTB verifies your authority to do so, you can move forward with filing your COLA application. To complete the application, you must upload an image of your label. The label must be a JPG or TIFF file and cannot exceed 750 KB in size. Along with a copy of your label, you will need to provide the TTB with the following information about each label:

  • your DBA/Trade Name (if any);
  • your brand name;
  • your product’s fanciful name (if any); and
  • the size of the actual printed label.

Once you’ve submitted your application, a TTB officer will usually respond within two weeks. The TTB provides up-to- date processing information for label application on its website.

The tricky part of filing a COLA application is making sure that the label meets all federal regulations. This requires a careful review of the regulations regarding labeling and may also require you to allow the TTB to analyze a sample of your product. For more information about labelling requirements and TTB sample analyses see the following related articles:

Under the law, beer (generally called “malt beverage”) containers must be labeled with government- approved labels before they can be sold. In some cases, before the TTB will accept a Certificate of Label Approval (“COLA”) application, it will require applicants to submit information about their product and may also require a product sample for laboratory testing. The TTB refers to these submissions as “pre-cola product evaluations.”

What is the purpose of the pre-cola evaluation?

The purpose of the pre-cola evaluation is to ensure that your product doesn’t contain prohibited ingredients or too much of an ingredient that’s use is limited under the law.

Formula Evaluations.

Domestically produced alcohol products are most likely to be subject to a type of pre-cola product evaluation referred to as formula evaluations. The TTB website lists the wine, malted beverage, and distilled spirits that require formula evaluations before a COLA application can be submitted.

For malt beverages, the TTB most commonly requires a formula evaluation for specialty products such as flavored beer. For example, a formula must be filed for beer flavored with chocolate extract or syrup.

Minimum Formula Submission Requirements.

You can submit formulas through the TTB’s electronic system, Formulas Online. At a minimum, you will likely need to provide the TTB with the following information:

  • The alcohol content both immediately after fermentation and of the finished product;
  • The approved formula number for any beer base used in producing the current product;
  • Ingredient information for products made with manufactured flavoring including:
    • The name of any flavor;
    • The product number and TTB approval date of flavor;
    • The name and location of the flavor manufacturer; and
    • The point at which the flavor was added to the product.
  • Ingredient information for products made with flavoring and/or other nonbeverage ingredients containing alcohol including:
    • The volume and alcohol content of the beer base;
    • Maximum volume of flavor and/or other nonbeverage ingredients containing alcohol that will be used;
    • The alcoholic strength of any flavors and other nonbeverage ingredients contacting alcohol; and
    • The overall alcohol addition to the product through flavors/ nonbeverage ingredients containing alcohol.
  • The final volume and alcohol content of the finished product.

Other Documents You May Have to Submit.

A flavored ingredient data sheet (“FID”) is a spreadsheet that includes information about ingredients used in compound flavors. A compound flavor is a flavor consisting of multiple ingredients that are combined to produce a particular taste. If you use a compound flavor purchased from a flavor manufacturer in your product, you will need to submit a FID with your formula. The flavor manufacturer should be able to provide you with a FID when you purchase the flavors.

A limited ingredient calculation worksheet is a tool used to calculate the total amount of limited-use ingredients in your product. The limited ingredient calculation worksheet should only be used for products containing a compound flavor. Most of the time, you’ll be able to use the information provided in your FIDs to complete the limited ingredient calculation worksheet. You can obtain a limited ingredient calculation worksheet on the TTB website.

An ingredient specification sheet lists the contents of an ingredient used to complete your product. When submitting your formula, you should include a specification sheet for each ingredient that is made from more than one component (with the exception of compound flavors for which you should submit a flavored ingredient data sheet). For example, if your product is made from a juice made of sugar, water, and lemon, you will likely need to submit a specification sheet listing those components. You should be able to obtain the ingredient specification sheet from the ingredient manufacturer.

Learn More

For more information on labeling regulations and approvals, see our resource pages:

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