COLA for Products in Individual Boxes

[ChachasKatsi]

Hey everyone,

 

Quick question. We're working on a private label order that we've already gotten the bottle labels approved for. The customer now wants each of these bottles to be in individual opaque boxes. Does the box art/design need to also be approved in a separate COLA? 

 

Thanks!

[JNorris]

I did a product in a box where none of the labels were visible.  I spoke to the Marketing section of the TTB and was informed that if the brand labels were not visible, then the approved label would need to be on the packaging so that the customer knew what was in the box.  That is why so many gift boxes etc. have clear fronts.

They may still have an option where you can speak to them about Marketing.  It was option 5, but that may have changed.  I would call and verify so that you have the info straight from them.

[dhdunbar]

Try this for a definitive answer.  It is a matter of knowing that the key word for which to search is "carton."

 

§5.41   Bottle cartons, booklets and leaflets.

(a) General. An individual covering, carton, or other container of the bottle used for sale at retail (other than a shipping container), or any written, printed, graphic, or other matter accompanying the bottle to the consumer buyer shall not contain any statement, design, device, or graphic, pictorial, or emblematic representation that is prohibited by §§5.31 through 5.42 on labels.

(b) Sealed opaque cartons. If bottles are enclosed in sealed opaque coverings, cartons, or other containers used for sale at retail (other than shipping containers), such coverings, cartons, or other containers must bear all mandatory label information.

(c) Other cartons. (1) If an individual covering, carton, or other container of the bottle used for sale at retail (other than a shipping container) is so designed that the bottle is readily removable, it may display any information which is not in conflict with the label on the bottle contained therein.

(2) Cartons displaying brand names and/or designations must display such names and designations in their entirety—brand names required to be modified, e.g. by “Brand” or “Product of U.S.A.”, must also display such modification.

(3) Specialty products for which a truthful and adequate statement of composition is required must display such statement.