Almost every alcohol beverage needs a Certificate of Label Approval (COLA) from the Alcohol and Tobacco Tax and Trade Bureau (TTB) before it can be sold in interstate commerce. The federal labeling rules for wine, malt beverages, and distilled spirits are detailed and, in many cases, subjective. Lindsey Zahn P.C. reviews labels before submission and manages the COLA process through approval.
Mistakes caught during review mean delays, redesigns, reprinting costs, and missed launch windows. Mistakes that slip through are not safe either: TTB can later ask a company to pull a label, or the product, from the market. Drawing on years of advocacy before TTB’s Advertising, Labeling and Formulation Division (ALFD), the firm assesses risk before you submit and builds strategies when a label comes back needing correction.
How the firm helps
- Review draft labels for wines, malt beverages, distilled spirits, meads, and hard ciders against federal labeling regulations
- Draft and submit COLA applications and advise on label strategy for formulated beverages
- Analyze “needs correction” feedback using the regulations and prior approvals
- Develop arguments for issues that appear to be subjectively disapproved
Recent representations
- Reviewed distilled spirits labels for a co-packer’s clients and flagged compliance and legal issues
- Served as outside counsel to an importer whose products in the market did not match the COLAs on file
- Advised a new importer on a use-up request for stock purchased with non-compliant labels
- Obtained FDA pre-market approval for a material in a distilled spirits product that was not designated GRAS and did not appear on FDA’s Food Additive Status List
Prior results do not guarantee a similar outcome.
Frequently asked questions
Does every alcohol product need a COLA?
Almost every wine, malt beverage, and distilled spirit sold in interstate commerce needs one. Some products, such as wines under 7% alcohol by volume and beers that are not malt beverages, are labeled under FDA rules instead.
What if TTB returns my label as “needs correction”?
The firm reviews TTB’s feedback against the regulations and prior approvals, recommends changes, and where appropriate develops arguments supporting your original approach.
Can an approved label still be a problem?
Yes. If TTB later finds an issue, it can ask you to remove the label or product from the market. A review before submission reduces that risk.