For some, a craft spirits label redesign can be a joy, for others it can be a nightmare. There are very specific guidelines of what you can and cannot change that do not require you to re-submit a COLA – Certificate of Label Approval, application to the TTB. Keeping it simple can save you a lot of time and aggravation. Change too many things and you will be slowed down by being forced to get re-approved and as they say, time is money.
In this case, we did a complete refresh of Woodinville Whiskey Company’s much out-of-date White Dog package design. The label was surgically redesigned to reflect the current brand image and family with Woodinville’s other popular whisky products – all this without the need to re-submit a COLA application to the TTB. All informational content is, letter-for-letter, the same as the COLA approval from four years ago and therefore falls under the TTB “Allowable Changes” provision and requires no further review and no 60-day-plus waiting period – from inspiration to production in record time.
As for the unique attributes of this product – the monochromatic layout, snow-white paper and silver foil were carefully coordinated to emphasize the liquid’s crystal-clear, pure nature – in stark, gleaming contrast to the warm tones used with the aged products.
List of Allowable Changes to Approved Labels According to TTB
23 conditions exist under which labels can be changed without applying for a new certificate of label approval. For example, the addition of an internet address is one of these allowable conditions. Visit the TTB site for the complete list. For the latest data check the reverse side of this TTB form: TTB F 5100.31, Application for and Certification/Exemption of Label/Bottle Approval
Example from TTB Site
Here is a side by side example of some of the things that you can change on your label without having to get approval. These guidelines are up to date as of the posting of this story. You should always go directly to the TTB site for the latest guidelines when you are ready to update your labels.
In this example, the following changes were made (“allowable revisions”) to the approved brand label:
- Removed lighthouse illustration (item 1)
- Removed fanciful name “Guiding White” (item 1)
- Changed shape of label (item 3)
- Changed color of background and fonts
- Added a vintage date
- Changed alcohol content statement (item 11)
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