class/type on labels

[Sorghumrunner]

I've got a couple of COLA's that just came back for correction and I'm confused. I have a Rum that had Amber Rum on it's own line and am being told I have to have the word RUM on it's own line, Amber must be above or below it. I'm looking at lots of labels that have other words like Gold or Dark or Amber, or even just other descriptors next to the word Rum on their front label. What's the deal?

Same thing with a brandy, I put the name of our county next to the word Brandy and was told that must be on another line. Is there any argument around this?

[John McKee]

Hey,

Honestly, you probably aren't going to like this answer, but the answer is...yep, others have done it and your approver has said no.....which means that you can't.

Ok..so caveat to all of that. This isn't a plug, he's just damn good and very reasonably priced. Call Bob Lehrman (see below). If your point can be argued successfully, he's the guy. I've used him for all of our labels and for labels that we run through our co-packing operation.

Sorry I didn't directly answer your question, but its the right answer...promise.

Best,

McKee

Robert C. Lehrman | 202-449-3739, ext. 1 (phone) | 202-478-5189 (fax) | www.bevlaw.com

[Lehrman Beverage Law, PLLC, 2911 Hunter Mill Road, Suite 303, Oakton, VA 22124.

[Sorghumrunner]

so how does that process work for you? you come up with your label design and then have Mr. Lehrman submit and communicate with TTB?

[John McKee]

That's exactly it, but the nice thing is that he does a pretty good review before he submits, which means that you're probably getting approved on the first pass through.