TTB recently released a new Certificate of Label Approval (COLA) form for alcoholic beverage labels, Form 5100.31, available here. The new form has several minor changes, but the most significant update is the expansion of the revisions that can be made to an approved label without having to submit a new COLA application. The new form should be a welcome change for industry members, who can now make more modifications to existing labels without waiting for TTB to approve the changes. The change is expected to significantly reduce the number of COLA applications submitted to TTB, thus reducing the turnaround time for new labels. The form became official early this month, and among the new revisions permitted to labels without the requirement of a new COLA application are:
- Re-position of label information, including text, illustrations, and graphics.
- Change of colors (background and text), font type and size, spelling and punctuation, and change from an adhesive label to one that is etched, painted, or printed directly on the container.
- Add a vintage date for wine labels (note that changing or deleting a vintage date was previously permitted, and the new form is only a change to the extent a vintage date is added where there was no vintage date previously).
- Change the optional “produced” or “made” by statements on wine labels to “blended,” “vinted,” “cellared,” or “prepared” by statements.
- Add, delete, or change UPC barcodes and/or 2D mobile barcodes, e.g., QR codes or Microsoft Tags (previously, only “UPC codes” were explicitly listed).
- Add, delete, or change trademark, copyright symbols (e.g., TM, ©), kosher symbols, company logos, and/or social media icons.
- Add, delete, or change information about awards or medals.
- Add, delete, or change holiday, and/or seasonal-themed graphics, artwork, and/or salutations.
- The new form also removes the requirement for separate COLA applications for packages that are 237 mL and below or 3 liters and above.
Contact one of the attorneys at Strike & Techel if you have questions about the new form or the COLA application process.
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