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If you’ve ever had a Certificate of Label Approval (COLA) rejected by the Alcohol and Tobacco Tax and Trade Bureau (TTB), you know how frustrating it can be. From seemingly minor formatting errors to incomplete statements of composition, label approvals can turn into bottlenecks that delay production and derail launches.
With TTB staffing still stretched thin and a growing queue of label submissions, distillers need every edge to get approvals right the first time. Here’s a guide to the most common COLA submission pitfalls and how to avoid them.
Misidentifying the Class and Type
This is one of the most frequent causes of rejection, particularly for specialty spirits, RTDs, or novel infusions. TTB class/type definitions haven’t kept pace with the rapid innovation in spirits, which means distillers must be extra careful when assigning categories.
Example Mistake: Labeling a product as “Gin” when it contains significant added flavors after distillation that would reclassify it as a “Distilled Spirit Specialty.”
Fix: Review the TTB Beverage Alcohol Manual (BAM) and Formula Wizard before submission. If in doubt, consult your approved formula: your product’s classification often hinges on what’s in that record. Pay special attention to the “Results” tab in TTB Formulas Online.
Unapproved Claims or Statements
TTB closely scrutinizes labels for unsubstantiated or prohibited claims, especially around health, natural/organic content, or novel production processes.
Example Mistake: Using “Gluten-Free” on a label without meeting TTB’s definition or having the supporting documentation.
Fix: Reference TTB’s Advertising and Labeling Policy and avoid loosely defined marketing terms unless backed by TTB’s published standards. If you’re referencing production methods or ingredients, make sure they’re documented in your formula and allowable on the label, and that you have good production & batching records to back up your claims.
Missing or Incomplete Statements of Composition
For any “Distilled Spirits Specialty” product, you’re required to use a statement of composition that reflects what the spirit actually is. This can’t just be a fanciful name, it must describe what’s in the bottle in regulatory terms.
Example Mistake: Calling your spirit “Maple Whiskey” when it’s actually a blend of neutral spirit and whiskey, flavored with maple syrup.
Fix: “Maple Whiskey” implies that the product is a Flavored Whiskey rather than Distilled Spirits Specialty. And, Flavored Whiskey may not have Neutral Spirit added. This is a subtle distinction. “Whiskey with Maple Syrup” would likely qualify as a Statement of Composition for this formula and product – under Distilled Spirit Specialties.
Accepting TTB’s Proposed Statement of Composition instead of making your own
When you file a Formula, part of the approval process involves the TTB Specalist proposing a “Statement of Composition” for the label. For the whiskey, neutral and maple product example above, a typical proposed SoC might be “Whiskey and Grain Neutral Spirits with Natural Flavors”. If you choose to use this SoC, it must appear on your label all in the same font size/precedence, even if it means wrapping to multiple lines.
Improve your marketability by proposing your own, alternative Statement of Composition on your label (COLA) submission. There is a surprising amount of flexibility here, as long as you accurately convey the nature of the spirits and avoid misleading consumers.
Inconsistencies Between Formula and Label
This one trips up even experienced producers. If you’ve submitted a formula, the ingredients and processes described there must align with what’s described on the label.
Example Mistake: Your formula includes lavender flowers, but the label says “Infused with Botanical Extracts”.
Fix: Cross-check the final formula approval with your proposed label. Ensure that changes in ingredients or production methods are captured in revised Formula submissions and COLA/Label submissions.
Final Tips for 2025
Use TTB’s Online COLA Checklist to flag obvious compliance issues before you submit.
Submit in off-peak times (avoid the holiday rush and Q1 backlogs).
Maintain a master checklist of required label elements and approval documents for each product SKU.
Track revisions in shared software (like DISTILL x 5 or another compliance platform) to prevent version mismatches across teams.
Getting a label approved on the first try saves time, money, and frustration. By steering clear of these common pitfalls, and keeping compliance aligned from formula to final artwork, you’ll keep your spirits moving from production line to retail shelf without delay.
