By Michael Kaiser
The TTB has issued updated guidelines for the approval of "personalized labels". In the past the TTB had allowed "templates" to be submitted for personalized labels. Meaning, the required information for the wine would be on the label, but the artwork could change. This allowed a winery to submit one label for many events, rather than having to submit a separate label for weddings, birthday, etc. A few years ago, the TTB started requiring new COLA submittals for any possible change in artwork. That meant that a winery would need to submit COLAs for any specific event they might do. This lead to increased work for wineries as well as the TTB.
Due to the dramatically increased turnaround times for COLA approvals, the TTB has now gone back allowing for a "template" for personalized labels. The standard is as follows:
In addition, the application must contain in item 19 of the paper application, or in the special wording section found in Part II/Step 2 in COLAs Online, a description of the specific personalized information that may change. For example, the application may state: “The graphics, salutations, dates, and artwork presented on this label may be changed to personalize this label.” For bottles etched with personalized information, the application must also indicate in item 19 of the paper application or in the special wording section found in Part II/Step 2 in COLAs Online that personalized information will be etched on the bottle. The label submitted with the COLA may contain a “blank” area where customized artwork or information will appear when the actual labels are printed.
Additionally all personalized labels will be approved with this qualification:
The approval of this COLA covers this label and any additions, deletions or changes in graphics, salutations, congratulatory dates and names, and artwork to personalize the label as indicated on the application. This approval to change the personalizing information does not permit the addition of any information that discusses either the alcohol beverage or characteristics of the alcohol beverage or that is inconsistent with or in violation of the provisions of 27 CFR parts 4, 5, 7or 16, as applicable, or any other applicable provision of law or regulations.
This is a step in the right direction for speeding up COLA turnaround times and WineAmerica suggested to TTB on numerous occasions to go back to template approvals for personalized labels. We applaud TTB for taking this step.
If you have any questions please feel free to contact us and if you wish to read the entire release from TTB it can be found here:
Public Guidance for Personalized Labels