One of the more common — and avoidable — issues we see during the TTB Certificate of Label Approval (“COLA”) process involves labels containing foreign language text without an accompanying English translation.
Although this issue may seem minor, it can result in a COLA application being placed in “Needs Correction” status, delaying approval timelines and potentially impacting production schedules, import clearances, or product launches.
For companies working within tight release timelines, even small application deficiencies can create costly delays.
Why TTB Requires Foreign Text Translations
When a wine, beer, or distilled spirits label contains wording in a language other than English, TTB generally requires the applicant to provide an accurate English translation as part of the COLA submission.
This requirement exists because TTB must evaluate all statements appearing on a label — including foreign language text — for compliance with federal labeling regulations.
Among other things, TTB reviews foreign language statements to determine whether they:
- Are misleading or deceptive;
- Make prohibited claims;
- Contain unauthorized health-related statements;
- Include improper geographic references; or
- Otherwise violate federal labeling standards.
Without a translation, TTB cannot properly assess the content of the label.
Common Situations Where This Issue Arises
Foreign language text appears frequently on imported alcohol beverages, but the issue is not limited to imported products.
We commonly see foreign wording used in:
- Brand names;
- Product descriptors;
- Geographic references;
- Family mottos or heritage statements;
- Production descriptions;
- Tasting notes;
- Marketing slogans; and
- Decorative label elements.
Even small amounts of foreign text — including isolated words or phrases — may trigger translation requirements during the review process.
Avoiding “Needs Correction” Delays
One of the easiest ways to avoid unnecessary delays is to ensure that all foreign text is translated accurately at the time the COLA application is submitted.
Applicants should avoid relying solely on automated translation tools where meaning or context may be unclear. In many cases, the best practice is to obtain a translation directly from the supplier, producer, or brand owner to ensure that:
- The translation reflects the intended meaning;
- Industry-specific terminology is interpreted correctly; and
- Contextual or cultural nuances are properly captured.
Providing a clear and complete translation upfront can often help prevent avoidable follow-up questions or correction requests from TTB reviewers.
Why Accuracy Matters
Translations that are incomplete, overly broad, or inaccurate can create additional compliance concerns.
For example, wording that appears purely decorative in another language may actually communicate:
- Aging claims;
- Quality statements;
- Production representations;
- Geographic indications; or
- Health-related messaging.
If these statements are inconsistent with TTB regulations or unsupported by the application materials, TTB may require revisions before approving the label.
Practical Considerations for Importers and Brand Owners
Companies importing alcohol beverages into the United States should carefully review all packaging components before submitting a COLA application, including:
- Front and back labels;
- Neck labels;
- Capsules;
- Cartons and outer packaging;
- Promotional neckers or tags; and
- Any additional packaging text visible to consumers.
Because translation issues are often identified late in the review process, proactive review can help reduce delays at the border and minimize disruptions to launch schedules.
How Our Firm Assists Alcohol Beverage Companies
Lindsey Zahn P.C. regularly assists wineries, breweries, distilleries, importers, and brand owners with:
- TTB COLA applications;
- Label compliance reviews;
- Foreign language translation issues;
- Advertising and marketing compliance;
- Formula and claim analysis; and
- Import-related regulatory matters.
We routinely work with clients to identify potential compliance concerns before labels are submitted to TTB, helping reduce approval delays and avoid costly revisions later in the process.
If you are developing an alcohol beverage label or have questions about labeling requirements, we invite you to contact our team to discuss how we can support your business.
📩 Email us at info@zahnlawpc.com
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