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Standard of Identity Change/COLA? Adding "Straight" to label


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We are now selling all our whiskeys and Bourbon at 2+ years old.  I looked at the allowable COLA changes on the TTB site but could not determine if adding the word "Straight" before Whiskey or Bourbon on my label was allowable or if need to submit revised COLAs.

Any thoughts?

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I think you could remove but not add it. That kind of makes sense, since there could be other information on a bottle of whiskey that was not approved as straight that could contradict it being a straight, but not obviously the other way around. Remember, the COLA is not saying you are actually putting this or that in the bottle, it is saying that the label is legal provided you are putting that in the bottle. Generally, the allowed changes without reapproval are those that could not create even an unintended conflict with the law. So, in our case, we resubmitted when adding "straight" to the description. Same for "bottled in bond".

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