Federal Certificate of Label Approval (COLA) basics

The Alcohol and Tobacco Trade and Tax Bureau (TTB) requires alcohol products to be labeled and marketed in accordance with Federal laws and regulations. Most alcohol producers and importers must apply for a federal Certification of Label Approval (COLA) to ensure that their product complies with these labeling and advertising regulations.

Applying for new COLA’s through ShipCompliant

1. In ShipCompliant, go to Registrations, then click Federal.
   
   
   
   
2. Click Add Label.
   
   
   
   
3. Choose Build NEW product or Clone or revise existing product.
   • If you’re building a new product, you’ll need to enter in all product information.
   • To revise an existing product, you’ll need to clone that products’ label first in order to make changes.
   • If most of your new products’ information is similar to an existing product, it’s sometimes easier to clone the label and then make any changes from there.
     
     
     
     
4. If you’re building a new product, select the product type and enter your TTB credentials to allow ShipCompliant to sync with the federal database. Then click Next.
   
   
   
   
5. If you’re cloning an existing product, search for the label you want to clone and click on it. In the popup window, click Clone.
   
   
   
   
6. Fill out or edit all relevant product information, and upload your label images.
   
   
   • ShipCompliant provides you with an estimated approval date for your COLA. This is based on TTB turnaround at the time of your application.
7. In each verification step, click on Find... and then highlight the appropriate text on the label in order to ensure your label complies with federal standards. Once you have verified all your label information, click Continue.
   
   
8. Review the conditions and instructions from the TTB, then provide your TTB login information to submit your COLA application.
   
   

Adding an existing COLA to your ShipCompliant account

1. In ShipCompliant, go to Registrations, then click Federal.
   
   
   
   
2. Click Add Label.
   
   
   
   
3. You can choose to either sync a COLA filed outside of ShipCompliant, or to add a label manually.
   
   
   
   
   • To sync a COLA from the TTB, enter its number, your TTB login information, or both. ShipCompliant pulls the COLA’s label information from the TTB site.
     
     
     • Edit label information.
     • Click Save to add the label.
       
         
       
       
   • To add a label manually, enter its basic information first. Fields in red are required. Then click the COLA tab, the Images tab, or others to add more details.
     
     

     If your label doesn’t have a COLA, you can skip this COLA section and enter in all other label information.

FAQ

What's the difference between a label and a COLA?

The words COLA and label are sometimes used interchangeably. They are related, but they aren’t the same thing. A label is what is applied to your packaging - it sometimes includes an image and relays specific information to potential buyers about your product such as ABV, container size, and the type of beverage. A federal Certificate of Label Approval (COLA) is a federal registration of your label. Not all labels need federal approval, but all COLA’s have labels.

I don’t have a COLA. Do I need one?

There are some exceptions to alcoholic beverages that need a federal COLA. Wines with an ABV below 7% are excluded from COLA requirements and are ineligible to receive a COLA. Similarly, only malt beverages that meet the definition of beer (made with both hops and malts) can receive a COLA. In addition, beers that are only sold in the state where they are produced aren’t required to get a COLA, though the brewer can still apply for a COLA for these products. And wines that aren’t sold in interstate or foreign commerce can receive a certificate of exemption from label approval, instead of a COLA, prior to bottling Read more about this on the TTB Wine FAQ webpage.

If a product doesn’t need or is ineligible to receive a COLA, label regulations under the Internal Revenue Code still apply, such as the Government Warning and proper standards of fill. Additionally, formula approvals may still apply for these COLA’s. Check with the Alcohol and Tobacco Tax and Trade Bureau (TTB) for requirements.

I don’t have a COLA. How do I register with the state?

In states where label registration is required, you can still apply for label approval if you don’t have a COLA. The registration process is similar to registering a label that has a COLA, only varying in that you’re required to manually enter label data that otherwise would be pulled in from a COLA. For example, label images for products with no COLA need to be entered manually, whereas this information is pulled from COLAs automatically.

What changes can I make to my COLA?

The TTB posts specific guidelines for allowable revisions - these are changes you can make to your label without needing to apply for a new COLA. Check out the TTB resources page for details.