Creating a compliant, compelling alcohol beverage label is far more than a design exercise—it’s a regulatory requirement. The Alcohol and Tobacco Tax and Trade Bureau (“TTB”) governs label approvals in the U.S., and if your label is missing required information or includes prohibited language, it can delay your go-to-market timeline or worse—trigger regulatory enforcement down the line.
Below are some of the most common and costly mistakes alcohol brands make when submitting labels to the TTB for approval.
1. Missing or Incorrect Mandatory Information
Every TTB-regulated label must contain certain mandatory elements depending on whether it’s wine, beer, or spirits. This includes:
- Brand name
- Class/type designation (e.g., Vodka, Red Wine)
- Alcohol content (formatted correctly)
- Net contents
- Bottler or importer’s name and address
- Government Warning Statement
- Sulfite declaration (for applicable wines and other products containing 10 ppm sulfites or more)
Labels missing even one of these components—or placing them incorrectly—can result in delays or rejection.
2. Improper Use of Health or Wellness Claims
Many brands want to lean into consumer trends by promoting their product as “healthy” or “hangover-free.” Unfortunately, such language often violates TTB or FTC guidelines. These terms may require scientific substantiation or fall under prohibited health-related claims.
Even if the label is attractive from a marketing perspective, it could be legally non-compliant or present risks to your company.
3. Inconsistent Alcohol Content Statements
The alcohol content must be:
- Precise within regulatory tolerances
- Written in a compliant format (e.g., “ALC 13.5% BY VOL”)
- Consistent across all labels, panels, and documentation
Incorrect formatting, improper rounding, or mismatch with your TTB formula can lead to a rejected application—or worse, a compliance headache later.
4. Unauthorized Geographic References
Referring to a geographic location (e.g., “Napa,” “Bordeaux,” “Tuscany”) requires compliance with specific standards. For example, under federal wine labeling regulations, calling a wine “Finger Lakes” means at least 85% of the grapes must come from that region.
Using geographic references without substantiation is one of the most common reasons TTB flags a label for correction.
5. Graphics or Symbols That Aren’t Allowed
TTB generally prohibits the use of certain:
- Government seals or flags;
- Currency image(s); or
- Misleading crests or badges that imply endorsement.
These types of symbols can trigger a correction request unless properly approved or explained in the application.
6. Submitting Labels Without Required Formula Approvals
Not all alcohol labels require formula approval, but when they do, a COLA cannot be issued until the formula is approved. A formula is typically required for products with certain flavorings, colorings, or unusual ingredients.
Many applicants jump the gun by submitting a label before checking whether a formula is required.
7. Using Terms That Don’t Match the Legal Class/Type
Calling your product “whiskey” when it’s a flavored whiskey, or “beer” when it doesn’t meet the regulatory definition, can create confusion and noncompliance. Make sure the terminology aligns with the TTB class/type definitions, not just your marketing vision.
Don’t Let Your Label Be the Bottleneck
TTB label approval is more than a formality—it’s a legal checkpoint that can directly impact your timeline, reputation, and product integrity. Whether you’re a new brand launching your first product or an established company rolling out something new, avoiding these common pitfalls can save you time, money, and frustration.
Lindsey Zahn P.C. helps alcohol beverage companies navigate TTB compliance with clarity and efficiency. We offer flat-fee label reviews, full-service COLA application assistance, and guidance on how to make your label marketable and compliant.
Contact us today to schedule a free introductory call and find out how we can help bring your label—and your brand—to life, the right way.