A TTB label approval feels final. It isn't — not entirely.
Once your COLA is approved, the TTB actually lets you make a whole set of changes to that label without refiling. Knowing which ones can save you a filing, a delay, and sometimes a reprint.
A few you can make on your own:
- Change the net contents to another authorized size
- Adjust the alcohol content, within the range for the class
- Add, change, or delete a vintage date
- Move or drop non-mandatory text; change type size, style, or color
- Add a UPC barcode, lot codes, or a bottling date
- Change to an address already approved, or a new one in the same state
And a few that still send you back for a new COLA:
- The brand name
- The class or type designation
- The appellation name (you can change the grape percentage — just not the name)
- The grape varietal
Rule of thumb: if it changes the mandatory identity of the product, refile. If it doesn't, you're likely clear — but check it against the TTB's own list before you reprint. Link to the entire article here.
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