TTB Certificate of Label Approval (COLA)

The COLA requirement traces its roots directly to the Federal Alcohol Administration (FAA) Act, signed into law by President Franklin D. Roosevelt in August 1935, just two years after the Twenty-first Amendment repealed Prohibition. The rapid and unanticipated ratification of the Twenty-first Amendment in December 1933 had caught Congress in recess, prompting Roosevelt to establish a temporary Federal Alcohol Control Administration (FACA) to manage the suddenly legitimate alcohol industry. FACA guided wineries and distilleries under voluntary codes for just twenty months before the permanent FAA Act replaced it. The FAA Act was written in direct response to the widespread fraud, adulteration, and consumer deception that characterized alcohol production during the Prohibition years (1920 to 1933), when unqualified home producers dominated wine supply and quality suffered severely. The Act authorized the Secretary of the Treasury to require label certification to prohibit consumer deception, ensure product identity, and provide adequate quality information. Today, TTB, a bureau of the U.S. Department of the Treasury, administers the COLA program under the authority of the FAA Act and enforces compliance with 27 CFR Part 4 for wine, 27 CFR Part 5 for distilled spirits, and 27 CFR Part 7 for malt beverages.

• The FAA Act of 1935 is the statutory basis for the COLA requirement, enacted two years after Prohibition's repeal to combat fraud and consumer deception.
• President Roosevelt first established the temporary FACA in 1933; the permanent FAA Act replaced it in August 1935, returning alcohol regulation to the Treasury Department.
• Wine COLA regulations are codified in 27 CFR Part 4; the health warning statement (required since the Alcoholic Beverage Labeling Act of 1988) is governed by 27 CFR Part 16.
• The FAA Act explicitly prohibits removing bottled wine from customs custody for commercial purposes without a valid COLA in the importer's possession.

Federal law draws clear lines around COLA applicability for wine. Any wine containing 7% alcohol by volume or more that will be sold, shipped, or otherwise introduced into interstate commerce requires a COLA before bottling. For importers, the FAA Act prohibits removing wine from U.S. Customs and Border Protection custody for any commercial purpose unless a valid TTB-issued COLA covering that wine is already in the importer's possession at the time of entry. This applies to table wines, sparkling wines, dessert wines, meads, and fruit wines above the 7% ABV threshold. Wines below 7% ABV fall outside the FAA Act's jurisdiction, and TTB has no authority to issue a COLA for them. Individual states may still impose their own label approval requirements for sub-7% wines. A narrow but important exemption exists for wines bottled exclusively for sale within the state of bottling: producers in that situation may apply for a Certificate of Exemption from Label Approval rather than a full COLA, though the exempted label must include the phrase 'For sale in [State] only.' Wines exported in bond without payment of tax are also exempt from the COLA requirement.

• COLA required for all wine at 7% ABV or above sold in interstate commerce or imported commercially; TTB has no authority to issue COLAs for sub-7% wines.
• Importers must hold a valid COLA before removing wine from U.S. Customs custody; the TTB-assigned COLA identification number must be filed electronically with CBP at entry.
• A Certificate of Exemption from Label Approval is available for wines sold exclusively intrastate; those labels must carry the statement 'For sale in [State] only.'
• Some wines (added flavors, aperitifs, sakés) require TTB formula approval before a COLA application can be submitted.

A COLA application must demonstrate that the wine label contains all elements mandated by 27 CFR Part 4. Certain information must appear on the brand label specifically, while other mandatory information may appear on any label affixed to the bottle. The brand label must carry the brand name, the class or type designation (which may be a varietal name, such as Chardonnay, if sourcing thresholds are met), and, when a vintage date or varietal designation appears, an appellation of origin. The brand label is formally defined as the label carrying the distinctive design and brand name of the wine. Additional mandatory disclosures, which may appear on any label, include: the name and address of the bottler or importer; alcohol content by volume; net contents; a sulfite declaration if the wine contains 10 parts per million or more of sulfur dioxide; and the government health warning statement required under the Alcoholic Beverage Labeling Act of 1988. For wines over 14% ABV, a numerical alcohol content statement is mandatory. Minimum font sizes are prescribed: at least 2 mm for containers larger than 187 ml, and at least 1 mm for containers of 187 ml or less. Images and graphics on labels are also regulated and may not create a misleading impression, per 27 CFR 4.39.

• Brand label must carry: brand name, class or type designation, and appellation of origin (mandatory when vintage, varietal, estate bottled claim, or semi-generic designation appears).
• Any label may carry: bottler or importer name and address, alcohol content, net contents, sulfite declaration, and the government health warning statement.
• Sulfite declaration is mandatory when total sulfur dioxide is 10 ppm or more; lab analysis must be submitted with the COLA application if a no-sulfite claim is made.
• Minimum font size is 2 mm for containers above 187 ml; graphics and images may not be misleading under 27 CFR 4.39.

Many of the most scrutinized elements of a wine COLA application involve claims that are only permitted if specific sourcing percentages are met. These thresholds are codified in 27 CFR Part 4 and are actively verified by TTB reviewers during the COLA process. A single grape variety may be listed as the type designation only if at least 75% of the wine is derived from that variety, all grown in the labeled appellation of origin. An American Viticultural Area (AVA) may be used as an appellation of origin only if at least 85% of the wine is derived from grapes grown within that AVA's boundaries. Wines bearing a state or county appellation require at least 75% of grapes from that geographic area. When two or more counties in the same state are listed as an appellation, 100% of the fruit must originate from those named counties, with the percentage from each county disclosed on the label. For vintage dating, wines carrying an AVA appellation must derive at least 95% of their volume from grapes harvested in the stated year; for state or county appellations the vintage threshold is 85%. The 'estate bottled' claim requires that all grapes come from vineyards owned or controlled by the winery, located within the same viticultural area where the winery is located and where the wine is bottled and finished.

• Varietal designation: minimum 75% of the named grape variety, all grown in the labeled appellation (27 CFR 4.23).
• AVA appellation: minimum 85% from within the named AVA; state or county appellation: minimum 75% (27 CFR 4.25).
• Vintage date: 95% from stated harvest year for AVA-designated wines; 85% for state or county appellation wines (27 CFR 4.27).
• Estate bottled: all grapes from vineyards owned or controlled by the winery, located in the same viticultural area as the bottling facility.

Since its introduction, the TTB's COLAs Online portal has streamlined what was once a paper-heavy approval process into a fully electronic system. Producers and importers must first register a business account with TTB, then log in to submit label applications. Each application requires uploading digital images of all labels that will appear on the bottle, selecting the correct beverage category and product class, and providing product details including alcohol content, brand name, and, where applicable, a TTB-assigned formula approval number for products requiring prior formula review. TTB's Alcohol Labeling and Formulation Division (ALFD) reviews each submission for compliance with federal labeling requirements, checking for truthful statements, required disclosures, and prohibited language or imagery. Typical processing takes between 5 and 20 business days for straightforward applications. If the application is approved, TTB issues the COLA, which carries a unique TTB identification number. If there are deficiencies, TTB will either reject the application or request revisions. Importers filing electronically with U.S. Customs and Border Protection must provide the TTB-assigned COLA identification number at the time of the customs entry filing. The public COLA registry on the TTB website allows anyone to search for previously approved COLAs, providing transparency across the industry.

• Applications submitted through the COLAs Online portal at ttb.gov; requires uploading all label images and providing product and bottler details.
• Standard processing time is 5 to 20 business days; products requiring formula approval must secure that first, before COLA submission.
• Approved COLAs carry a unique TTB identification number required for customs entry filings by importers.
• TTB maintains a publicly searchable COLA registry, allowing industry members and consumers to verify approved labels.

Obtaining a COLA is not a one-time, static event. Wine producers regularly update labels for new vintages, updated bottler information, or revised artwork, and understanding which changes require a new COLA versus which are permitted as allowable revisions is a practical compliance concern for any winery or importer. TTB publishes a detailed list of allowable revisions on its website. Non-mandatory information, such as decorative graphics or optional descriptive text, may generally be deleted or repositioned without a new COLA. However, adding or changing non-mandatory information, such as new graphic elements or optional statements, does require a new COLA application. Changes to mandatory label information always require reapplication. COLA holders must also maintain complete cellar records supporting any varietal, vintage, or appellation claims made on the approved label; those records must be available for TTB audit at any time. While a TTB-approved COLA authorizes a label for federal compliance, it does not insulate a producer from state consumer protection actions, as courts have held that TTB approval does not preclude state-level claims of misleading labeling. Some states also impose their own label approval requirements independent of the federal COLA, adding a further layer of compliance for producers seeking national distribution.

• Non-mandatory information (decorative graphics, optional text) may be deleted without a new COLA; adding or changing such information requires reapplication.
• Mandatory label information changes always require a new COLA submission.
• Cellar records substantiating varietal, vintage, and appellation claims must be maintained and available for TTB audit.
• TTB COLA approval does not protect producers from state-level consumer protection lawsuits, and some states have independent label approval requirements.