Product of....

[Oregon Spirit Distillers]

We submitted a label for COLA approval. We include the wording "Product of Oregon." on the front label. It was rejected.

"Reason: X"

"Additional information: Delete from brand label Product of Oregon this statement is required for imporetd products only."

Can I not include this on my label on a domestic bottle? Is there other acceptable wording?

Thanks,

Brad Irwin

Oregon Spirit Distillers

Product of Oregon

[FrEwing]

We submitted a label for COLA approval. We include the wording "Product of Oregon." on the front label. It was rejected.

"Reason: X"

"Additional information: Delete from brand label Product of Oregon this statement is required for imporetd products only."

Can I not include this on my label on a domestic bottle? Is there other acceptable wording?

Thanks,

Brad Irwin

Oregon Spirit Distillers

Product of Oregon

Great topic. I am also interested if there is other wording acceptable on the label that identifies that it is a local product. Also if one can not print it on the front label can it be included on the back label as part of the product story or description. For example: "XYZ spirit is hand crafted spirit made in Oregon using grains grown on small local farms and deep artisian water contributing to the distinct flavor etc etc etc'

[PeteB]

My label says "Made in Australia" so could "Made in Oregon" be approved.

[suzypingree]

Our label says made with Washington apples, and on the back it describes how the apples are harvested by us from our orchard.

[Curtis McMillan]

Made in ... (roll the dice)

[porter]

I 'believe' your key distinction here is in 'word meanings'.

"Product of Oregon" implies Oregon is a seperate entity from the US, and therefore Oregon is the producer.

"Made in Oregon", "Produced in Oregon", simply denotes where the product was made.

Regular food labels have same type of distinctions.

[Scott @ Twenty2Vodka]

Perhaps there was a misunderstanding by the COLA agent of your label's intent? Their feedback says "...this statement is required for imporetd products only". While your "Product of Oregon" it's not "required" for your non-imported product, you are choosing to include it anyway. I believe a 1 sentence doc explaining this to them would put the issue to rest. In my COLA experience, more than once I've replied to their comments in the manner of "This is why my original submission will remain unchanged." referencing exactly the spot of BAM or 27 CFR that supports my case. They've all been approved to date. TTB regs are lengthy but they state explicitly what is or isn't required. Everything else is "freedom" haha.

Good Luck,

-Scott

[Gwydion Stone]

What Scott said.

Maybe you could show them this. I just happened upon it this morning and it reminded me of your post.

[bluestar]

What Scott said.

Maybe you could show them this. I just happened upon it this morning and it reminded me of your post.

Yes, that label indicates the general use of "Product of" to denote country of origin for import/export purposes. "Produced by" or "Made by" an entity "in" a location should be allowable. Sounds like the COLA response was poorly worded: they might have been trying to indicate that the "Product of" wording on front label is reserved for import/export designations, and therefore a state would not be allowed?

[FrEwing]

Thanks - I.ve just gotten a post graduate education from you old masters

Dick Garofalo

FrEwing