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New TTB Guidance on COLAs

The TTB recently announced new guidance on personalized labels, which supersedes its prior guidance in TTB G 2010-1 from April 7, 2010. The guidance provided in 2010 did not allow changes to artwork or graphics on a personalized label without resubmission of the label for approval. The TTB has relaxed its view and now will allow changes to graphics and artwork on personalized labels without requiring application for a new certificate of label approval (“COLA”). Names, event dates and salutations can also be changed without applying for a new COLA, as was previously allowed under the 2010 guidance. Personalized labels are for use with targeted customers or clients for things like weddings and grand openings. They are distinct from private labels, which remain subject to the standard COLA requirements and require resubmission for a COLA when label artwork is changed.

In order to obtain this flexibility on personalized labels, such preference must be indicated on the initial COLA application and the information that may change must be described. The label must still contain all standard mandatory label information. When issuing the COLA approval for personalized labels the TTB will include a qualification stating that the COLA covers the label and any changes in “graphics, salutations, congratulatory dates and names, and artwork to personalize the label as indicated on the application.” The new guidance is available here. If you would like to discuss COLA applications, please feel free to contact any of the attorneys at Strike Kerr & Johns.


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