TTB’s Top Label/COLA Application Errors

TTB’s Top Label/COLA Application Errors & How to Take the Steps to Correct These Common Errors

Class/type designation is missing from the brand label – add a class and type such as red wine, a grape varietal or a statement of composition to your brand label. Keep in mind a wine color alone is not a class/type designation. For example, “Rosé Wine” is a class/type designation but “Rosé” is not.

Grape varietal(s) is missing from the application – when varietals are indicated on the label they must be listed on the COLA application as well.

Missing/conflicting brand name – brand name entered on the application must appear exactly as indicated on the brand label.

Bottler/Importer address conflict – the address in the bottler/importer statement on the label conflicts with the address on the COLA. The company address (City and State) in the bottler/importer statement must be identical to the address that appears on the bottler’s importer’s basic permit.

Trade name/DBA conflict – company name or DBA name on the label conflicts with the name in the bottler/importer statement on the COLA. The operating name or trade name in the bottler/importer statement on the label must be identical to the name that appears on the bottler’s importer’s basic permit. The trade name must be approved by the National Revenue Center (NRC)

Appellation is missing from the label – a wine product labeled with a grape varietal, vintage date, semi-generic type designation or the term “estate bottled” must also have an appellation of origin.

Appellation conflict – the appellation of origin stated in the appellation field is in conflict with the appellation stated on the brand label. All labels and application must reflect the same appellation of origin.

Formula/label contains conflicting information – the statement of composition on the label conflicts with the statement of composition indicated on the approved formula. The label information must be consistent with the approved formula.

Misleading geographical reference – Label contains a geographic reference that TTB considers misleading as it implies viticultural significance. The reference in question might include the name, or partial name of an AVA rendering the label non-compliant with TTB regulations.

Labels are distorted – results in blurry text/images that TTB is unable to evaluate. Compression ratio may need to be changed to medium or low so that file is within the accepted size limit of 750KB. Additional guidance can be found at https://www.ttb.gov/labeling/colas and click on “Prepare Images for Upload” located at the bottom of the page.

Health warning statement errors – most errors are punctuation, bold and capitalization errors. The words “Government Warning” must be in bold type and “Surgeon General” must be capitalized.

Missing translation of foreign text – if foreign text appears anywhere on the label TTB requires a complete and accurate translation. It can be provided in step 3 (“foreign translation”), in the “notes to specialist section” or uploaded as an attachment to your COLA.

Other countries’ warnings prohibited – TTB finds that some of the warning statements (text/pictorial references) required by other countries relating to the health effects of alcohol consumption may be confusing and/or misleading to the extent that they communicate different information form the heath warning statement required in the US. Therefore, it is TTB’s policy not to approve such statements on beverage alcohol labels.

Label clarification requested – the label specialist may return the COLA requesting additional information or clarification on things like abbreviated words, meaning of certain terms or graphics on a label. An explanation can be provided in the “notes to specialist” field or uploaded as an attachment to your application.

*Based on data supplied by the Alcohol and Tobacco Tax and Trade Bureau – 2020