Certificate of Label Approval: Filing, Exemptions, and Penalties

A Certificate of Label Approval, or COLA, is the Alcohol and Tobacco Tax and Trade Bureau’s written sign-off on the label of an alcoholic beverage before that product can move in interstate or foreign commerce. Every domestic bottler of distilled spirits, wine, or malt beverages needs one, as does every importer clearing product through customs for commercial sale. TTB charges no fee, and as of early 2026 median processing runs one day for malt beverages, two days for distilled spirits, and six days for wine.1Alcohol and Tobacco Tax and Trade Bureau. Processing Times for Label Applications The application itself is short. What slows people down is everything that has to be true before you file.

Who Has to Get One

The Federal Alcohol Administration Act requires anyone who bottles distilled spirits, wine, or malt beverages for sale in interstate or foreign commerce to hold a COLA before those products ship, and the same rule applies to importers.2eCFR. 27 CFR Part 5 – Labeling and Advertising of Distilled Spirits You cannot submit a COLA application without first having legal standing as a regulated industry member. Breweries need a Brewer’s Notice from TTB.3Alcohol and Tobacco Tax and Trade Bureau. Brewer’s Notice Distillers, wineries, and importers need a TTB Basic Permit. And any brand name that appears on the label has to be registered as a trade name on that permit or notice before you file.4eCFR. 27 CFR 24.112 – Name of Proprietor and Trade Names

Check Whether You Need Formula Approval First

Some products need TTB formula approval before a COLA application can even be filed. This applies most often to beverages with added flavoring or coloring materials, but reaches other non-standard products too.5Alcohol and Tobacco Tax and Trade Bureau. Formulation – Alcohol Beverage Formula Approval Submit a COLA without the required formula ID and TTB rejects the application outright.

TTB publishes interactive tools that walk through whether a specific spirit, wine, or malt beverage requires formula approval.6Alcohol and Tobacco Tax and Trade Bureau. Which Alcohol Beverages Require Formula Approval Once your formula is approved, you receive a formula ID that goes on the COLA application.7Alcohol and Tobacco Tax and Trade Bureau. Formulas Online User Guide Run this check early in product development, not after you’ve had labels printed.

What Has to Be on the Label

Three separate regulations govern label content depending on the beverage: 27 CFR Part 4 for wine, Part 5 for distilled spirits, and Part 7 for malt beverages.8eCFR. 27 CFR Part 4 – Labeling and Advertising of Wine The details differ, but every label must carry the same core information:

Brand name, class and type, and alcohol content have to appear in the same field of vision, so a consumer sees all three without turning the container.2eCFR. 27 CFR Part 5 – Labeling and Advertising of Distilled Spirits Net contents and the name and address can sit anywhere on the container.

Minimum type sizes are strict and vary by beverage type and container volume. Most mandatory information runs at least 2 millimeters on larger containers and 1 millimeter on smaller ones, with wine alcohol statements capped at 3 millimeters on containers of 5 liters or less.11eCFR. 27 CFR 4.38 – Type Size of Mandatory Information for Wine12eCFR. 27 CFR 7.53 – Type Size of Mandatory Information and Alcohol Content Statements The health warning has its own scale — 1 millimeter on containers up to 237 milliliters, 2 millimeters up to 3 liters, and 3 millimeters above that — with “GOVERNMENT WARNING” in bold capitals, the rest not bold, and the whole statement set on a contrasting background separated from other label copy.13eCFR. 27 CFR 16.22 – General Requirements for Health Warning Statement Confirm the exact thresholds for your container size in the CFR section that applies to your product before submitting.

How to File

All COLA applications go through COLAs Online, TTB’s electronic filing system.14Alcohol and Tobacco Tax and Trade Bureau. COLAs Online Electronic Filing System Registering for an account requires the premises address from your permit or notice. If you’re filing on behalf of a company you don’t own, a valid Signing Authority or Power of Attorney form has to be on file at TTB’s National Revenue Center before you register.15Alcohol and Tobacco Tax and Trade Bureau. Register for a New Formulas Online and/or COLAs Online Account Get that paperwork in first.

The application is TTB Form 5100.31.16Alcohol and Tobacco Tax and Trade Bureau. TTB F 5100.31 – Application for and Certification/Exemption of Label/Bottle Approval Inside COLAs Online you enter the same fields — brand name, class and type, alcohol content, net contents, container size — and upload a high-resolution image of the label exactly as it will appear on the bottle, with all final colors and fonts. Formula ID goes in the same submission if formula approval was required. The system issues a tracking number when you submit.

TTB’s stated goal is to complete 85% of applications within 15 days, and current medians run well below that. You can watch your submission status in COLAs Online. If the specialist finds problems, the status shifts to Needs Correction and you can fix the issues in the same filing rather than starting a new one.

Why Applications Get Sent Back

TTB has said the most common causes of returns and delays are ordinary mistakes: missing net contents, type below the minimum size, alcohol content that does not match the approved formula, or a health warning formatted incorrectly. The agency publishes mandatory labeling information checklists for each beverage category that mirror what specialists look at during review.17Alcohol and Tobacco Tax and Trade Bureau. Avoid Common Labeling Errors – Use Mandatory Labeling Information Checklist Running the applicable checklist against your artwork before you submit is the single easiest way to avoid a correction cycle.

If TTB Denies or Qualifies Your Approval

You have 45 days from the date of the notice to file a written appeal of a denial or of qualifications you disagree with. Miss the window and the decision becomes final.18eCFR. 27 CFR 13.25 – Appeal of Qualification or Denial Full appeal and revocation procedures are in 27 CFR Part 13.19eCFR. 27 CFR Part 13 – Labeling Proceedings

How Long the Approval Lasts

An approved COLA generally does not expire. A small number are issued with temporary approval and a specific expiration date, and when that happens the certificate itself carries qualifications explaining why. In those cases you need a new COLA before bottling can continue past the date. Otherwise the approval stands as long as the label doesn’t change beyond what TTB treats as an allowable revision.

Changes You Can Make Without a New COLA

TTB’s list of allowable revisions is broader than most producers expect. You can change background or text color, alter label shape or proportion, swap fonts, add a vintage date, update alcohol content or net contents, add a QR code or website, remove illustrations, or shift a producer statement (for instance, “Produced by” to “Vinted by”).20Alcohol and Tobacco Tax and Trade Bureau. List of Allowable Changes to Approved Labels The limits are that mandatory information must stay legible on a contrasting background, spelling changes cannot alter the meaning of previously approved information, and you cannot split one approved label into multiple labels without a new COLA.21Alcohol and Tobacco Tax and Trade Bureau. Allowable Revisions to Approved Labels The complete list with conditions sits on pages 3 and 4 of Form 5100.31. Check it before filing an application you might not need.

Personalized Labels for Weddings and Events

If you sell bottles with customized text for weddings, anniversaries, or corporate events, a single COLA can cover ongoing personalization if you set it up correctly at the start.22Alcohol and Tobacco Tax and Trade Bureau. Personalized Labels Submit a template label and describe the specific elements that will change — messages, names, dates, artwork — in the special wording section of COLAs Online. That description has to be in the application itself, not in a side note to the specialist. Personalized content cannot alter any mandatory label information, cannot discuss the beverage or its characteristics, and remains subject to the standard prohibitions, including on misleading health claims. Private labels made for retailers or restaurants are not covered by this guidance and go through the standard COLA process.

When You Can Skip the COLA

Products that will never leave the state where they are produced can be filed under a Certificate of Exemption from Label Approval instead of a full COLA, using the same Form 5100.31. The applicant has to show the product will not enter interstate or foreign commerce.23eCFR. 27 CFR Part 5 Subpart B – Certificates of Label Approval and Certificates of Exemption from Label Approval The label must include the statement “For sale in [name of State] only.” Omitting it can cause the product to be treated as an uncertified interstate item and expose you to standard labeling penalties. A federal exemption also does not touch state labeling rules, which still apply.

What Non-Compliance Costs

Violating the FAA Act’s labeling requirements is a federal misdemeanor with a fine of up to $1,000 per offense.24Office of the Law Revision Counsel. 27 USC 207 – Penalties TTB can also suspend or revoke a basic permit for willful violations, which stops operations.

The health warning statement carries a separate civil penalty under the Alcoholic Beverage Labeling Act of 1988. For violations assessed on or after January 16, 2025, the penalty runs up to $26,225, and each day a violation continues counts as a separate offense.25Alcohol and Tobacco Tax and Trade Bureau. Alcoholic Beverage Labeling Act Penalty TTB can also revoke a previously approved COLA if it later determines the label does not comply, with 45 days for the holder to respond before revocation becomes final.

State Registration Is a Separate Job

A federal COLA is necessary but rarely enough on its own. Most states require their own label registration or approval before an alcoholic beverage can be sold within their borders. Fees, timelines, and specific requirements vary by state; some charge nothing, others assess per-label costs. If you plan to distribute in twenty states, plan for twenty separate registrations on top of the federal COLA and budget the time before you commit to a launch date.