Certificates of Label Approval (COLAs)
Learn what a COLA is and explore some frequently asked questions about them.
The Alcohol and Tobacco Trade and Tax Bureau (TTB) requires alcohol products to be labeled and marketed in accordance with Federal laws and regulations. Most alcohol producers and importers must apply for a federal Certification of Label Approval (COLA) to ensure that their product complies with these labeling and advertising regulations.
What's the difference between a label and a COLA?
The words COLA and label are sometimes used interchangeably. They are related, but they aren't the same thing. A label is what is applied to your packaging - it sometimes includes an image and relays specific information to potential buyers about your product such as ABV, container size, and the type of beverage. A federal Certificate of Label Approval (COLA) is a federal registration of your label. Not all labels need federal approval, but all COLA's have labels.
I don't have a COLA. Do I need one?
There are some exceptions to alcoholic beverages that need a federal COLA. Wines with an ABV below 7% are excluded from COLA requirements and are ineligible to receive a COLA. Similarly, only malt beverages that meet the definition of beer (made with both hops and malts) can receive a COLA. In addition, 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 a certificate of exemption from label approval, instead of a COLA, before 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 for these COLA's. Check with the TTB for requirements.
I don't have a COLA. How do I register with the state?
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, only varying in that you're required 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.
What changes can I make to my COLA?
The TTB posts specific guidelines for allowable revisions - these are changes you can make to your label without needing to apply for a new COLA. Check out the TTB resources page for details.