If you\u2019ve 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.<\/p>\n\n\n\n
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.<\/p>\n\n\n\n
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This is one of the most frequent causes of rejection, particularly for specialty spirits, RTDs, or novel infusions. TTB class\/type definitions haven\u2019t kept pace with the rapid innovation in spirits, which means distillers must be extra careful when assigning categories.<\/p>\n\n\n\n
Example Mistake<\/strong>: Labeling a product as “Gin” when it contains significant added flavors after distillation that would reclassify it as a \u201cDistilled Spirit Specialty.\u201d<\/p>\n\n\n\n Fix<\/strong>: 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\u2019s in that record. Pay special attention to the “Results” tab in TTB Formulas Online.<\/p>\n\n\n\n <\/p>\n\n\n\n TTB closely scrutinizes labels for unsubstantiated or prohibited claims, especially around health, natural\/organic content, or novel production processes.<\/p>\n\n\n\n Example Mistake<\/strong>: Using \u201cGluten-Free\u201d on a label without meeting TTB\u2019s definition or having the supporting documentation.<\/p>\n\n\n\n Fix<\/strong>: Reference TTB\u2019s Advertising and Labeling Policy and avoid loosely defined marketing terms unless backed by TTB\u2019s published standards. If you’re referencing production methods or ingredients, make sure they\u2019re documented in your formula and allowable on the label, and that you have good production & batching records to back up your claims.<\/p>\n\n\n\n <\/p>\n\n\n\n For any \u201cDistilled Spirits Specialty\u201d product, you\u2019re required to use a statement of composition that reflects what the spirit actually is. This can\u2019t just be a fanciful name, it must describe what\u2019s in the bottle in regulatory terms.<\/p>\n\n\n\n Example Mistake<\/strong>: Calling your spirit \u201cMaple Whiskey\u201d when it\u2019s actually a blend of neutral spirit and whiskey, flavored with maple syrup.<\/p>\n\n\n\nUnapproved Claims or Statements<\/h3>\n\n\n\n
Missing or Incomplete Statements of Composition<\/h3>\n\n\n\n