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Selling beer, wine and spirits in the US

In the US, the Alcohol and Tobacco Tax and Trade Bureau (TTB) regulates the labelling of alcohol beverages, working with the FDA on safety. Distilled spirits bottled in the US need a certificate of label approval before bottling, labels carry set information in one field of vision, and alcohol beverage containers carry the government health warning.

Updated · Each section links to the official source it comes from

Who regulates labels
TTB, working with the FDA
Label approval
A COLA, applied for in COLAs Online
Health warning
On alcohol beverage containers, since the 1988 Act
Spirits labels
Brand, class or type, and alcohol content together
States
Licensing and sale rules vary by state

Before a product goes on sale

The questions to answer, in the order they usually come up.

  1. 1Does the label need a certificate of label approval? Read more
  2. 2Does the label carry the mandatory information in one field of vision? Read more
  3. 3Is the government health warning on the container? Read more
  4. 4Which states will it be sold in? Read more

The rules, by area

What each area covers, the texts that set it, and what the official pages say.

Label approval

The certificate a label needs before the product is bottled or sold.

  • No person may bottle distilled spirits in the US without first applying for and obtaining a certificate of label approval (COLA) from TTB (27 CFR 5.21).
  • COLAs are applied for online through COLAs Online, with no fee to apply.
  • TTB publishes a public registry of approved labels.

How we help: Compliant Always keeps each COLA with the label it covers, so a change to the label shows which approval it needs. Ask about this

Mandatory label information

What the label shows, and the health warning.

  • Distilled spirits labels show the brand name, the class, type or other designation, and the alcohol content in the same field of vision (27 CFR 5.63).
  • Elsewhere on the container they show the name and address of the bottler, distiller or importer, and the net contents.
  • The Alcoholic Beverage Labeling Act of 1988 requires a government warning statement on alcohol beverage containers; its wording is set in 27 CFR 16.21.
  • TTB and the FDA work together on the safety of alcohol beverages.

How we help: Compliant Always sets your label beside the mandatory information for its class, with the regulation for each. Ask about this

Who answers for what

WhoWhat they answer forHow we help
Producer or bottlerThe label, its approval and the mandatory information.Labels and approvals kept together, with the regulation for each line.
ImporterIts name and address on the label, and the label approval for what it brings in.The producer's documents read and dated before the goods arrive.
DistributorSelling under the licensing rules of each state.The documents each product needs, shown when a retailer asks.

Federal and state

TTB sets federal labelling and permit rules. Each state sets its own rules on licensing and sale, which a product meets as well as the federal ones.

Questions businesses ask

Who regulates alcohol labels in the US?
The Alcohol and Tobacco Tax and Trade Bureau (TTB), which works with the FDA on the safety of alcohol beverages.
What is a COLA?
A certificate of label approval or exemption from TTB. Distilled spirits bottled in the US need one before bottling, and applications are made through COLAs Online, with no fee to apply.
What has to appear together on a spirits label?
The brand name, the class, type or other designation, and the alcohol content, in the same field of vision (27 CFR 5.63).
What else does a spirits label show?
The name and address of the bottler, distiller or importer, and the net contents, anywhere on the container.
Is a health warning required on alcohol in the US?
Yes. The Alcoholic Beverage Labeling Act of 1988 requires a government warning statement on alcohol beverage containers. Its wording begins 'GOVERNMENT WARNING:' (27 CFR 16.21).
Can I check whether a label was approved?
Yes. TTB keeps a public COLA registry that can be searched.
Do states have their own alcohol rules?
Yes. Licensing and the rules on sale are set by each state, on top of the federal labelling rules.
How does Compliant Always help with selling in the US?
Our team reads the rules for the markets you sell in. Compliant Always shows which apply to your product, keeps the documents behind each one ready, and watches federal sources for changes. It shows what the requirements say and what your documents show; you decide.

Sources

Compliant Always is a product of Lettuce Labs LLC. It shows what requirements say and what your documents show. It is not legal advice, and you decide.

Tell us what you make, and we will show you the rules for it.

Name the product and the markets you sell in. We will come back to you with what applies in the US and what your paperwork needs to show.

Get in touch

No card, no account, and no call to book. Tell us what you make and where you sell it, and we will come back to you.

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