Wines with an ABV below 7% are excluded from COLA requirements and don't need a COLA. Similarly, only malt beverages that meet the definition of beer (made with both hops and malts) can receive a COLA. Beers that are only sold in the state where they are produced aren't required to get a COLA, though the brewer can still apply for a COLA for these products. And wines that aren't sold in interstate or foreign commerce can receive aCertificate of Exemption from Label Approval, instead of a COLA, prior to bottling. Read more about this on the TTB Wine FAQ webpage.

If a product doesn't need or is ineligible to receive a COLA, label regulations under the Internal Revenue Code still apply, such as the government warning and proper standards of fill. Additionally, formula approvals may still apply. Check with the Alcohol and Tobacco Tax and Trade Bureau (TTB) for requirements.

In states where label registration is required, you can still apply for label approval if you don't have a COLA. The registration process is similar to registering a label that has a COLA. You'll need to manually enter label data that otherwise would be pulled in from a COLA. For example, label images for products with no COLA need to be entered manually, whereas this information is pulled from COLAs automatically.