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COLA Allowable Revisions

Max Action

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We are still fine-tuning our branding and label design with our graphic designer, but anxious to hurry up and get our labels submitted for COLA.

Looking at the Allowable Revisions to Approved Labels makes me wonder if I souldn't submit right away. It seems most all non-mantadory text and graphics can be changed later without a new approval. It makes me wonder if I shouldn't just submit a generic label with our mandatory elements now (i can make that myself in MS Word) and worry about the aesthetics later. Any flaws with that logic? All the other label approvals I see appear to be final artwork, so it makes me wonder if I'm missing anything.

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I can't comment whether what you describe is a good idea or a bad idea, but you might as well factor in this nice little tid bit of info that they will include on your eventual "Approval":

"TTB has not reviewed this label for type size, characters per inch or contrasting background. The responsible industry member must continue to ensure that the mandatory information on the actual labels is displayed in the correct type size, number of characters per inch, and on a contrasting background in accordance with the TTB labeling regulations, 27 CFR parts 4, 5, 7, and 16, as applicable."

What do these guys do again except for delay the process by a month? i dunno....

At least it's "free" and digital, for now.


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We did it this way for a limited release brandy that we are selling in the tasting room only. But the finished "label" was handwritten on the glass bottle with a metallic paint pen.

There are some requirements that may make your approved generic and then finished label not work. The COLA approval process ensures that there are enough contrast in the decoration to be able to read the info, some items must be visibly separate from others. This is easy to do in word but when you get your finished label it may not be so obvious.

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