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  • ttb, labels, and keg only

    So we got our state license approval more quickly than anticipated.

    We are distributing kegs only and plan to just use collars either from the printable generic or the plastic generic. The way i understand the collar itself is the label with our info it - is that what other folks are doing? Right now we have no need for graphics or real 'labels' so we figure the minimum to appease the ttb. I have also seen recent news of ttb requiring stick-on collars and wonder if our cola will suffer from this.

    Chris
    _______________________
    Chris Burcher, Wolf Hills
    Abingdon, VA

  • #2
    The best place to check is at TTB's website. Here's a link to the Basic Mandatory Labeling http://www.ttb.gov/beer/bam.shtml

    I don't handle the labeling approval process for our company, so I don't want to take the chance of misleading you on the details. However, our keg collar labels feature only the basics: the name of the brewing company, the location of the business, the brand name of the beer, the net contents, the date of packaging, and the properly formatted government warning. We also have permanent stickers with the government warning affixed to the kegs.

    If there's any doubt, contact them directly. It's better than finding out when an inspector notes that your label is in violation of a particular requirement.

    Interesting fact: if your brewery has a t-shirt that features a picture of your beer in its packaging-a picture of a bottle of your beer, for example-the displayed label must match the label that was approved by TTB, other wise it's a violation. T-shirts featuring images of your beer are considered advertising and must also meet their requirements.
    Last edited by MJMurphy; 08-24-2009, 09:01 PM.

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    • #3
      Hey there. Off the top of my head, the basics are: name of the beer, "Brewed and Kegged by...", volume in the container, alcohol by volume (if required by your state) and the government warning. Really, the easiest way to figure out if your keg label is ok is to submit it through COLAs online and let them tell you what to change. Easier and cheaper than hiring a lawyer to do the same thing.

      Also, there's a good chance that you may not need to get TTB label approval if you're only distributing in-state. Give them a call and say "I'd like your guidance on how I can be in compliance with your regulations..." and they will generally happily walk you through what you need to do. It actually saves them time and energy.

      A short fix is to go to Triad Products and buy a bunch of generic rings and fill in your info with a sharpie, scan it and send that in for COLA approval.

      Here: http://triadproducts.net/catalog/cat...53fe7eacbcd5f7

      Good luck.
      Kevin McGee

      Healdsburg Beer Company
      Sonoma County, California

      "Because this town sure didn't need another winery."

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      • #4
        Thanks guys.

        Gordie, the 2nd part of what you said is what I am wondering about - we're only instate. I will call ttb and ask specifically about that. Last time I asked, "what label do I need to distribute kegs" and they, of course, referred me to their guidelines (which I don't understand, that's why I called them) and said "everything needs a label". I think being more specific will help.

        Murphy, that t-shirt deal is a hoot.

        Our plans are to get the triad collars and fill 'em in for now, it just sucks to have to get them approved being so generic and all.
        _______________________
        Chris Burcher, Wolf Hills
        Abingdon, VA

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        • #5
          Sent you a PM with my number..... Call me I have some info for you.

          Mike
          Mike Pensinger
          General Manager/Brewmaster
          Parkway Brewing Company
          Salem, VA

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          • #6
            Had a boring conference call and my fingers started doing research:

            27 United States Code, Chapter 8, Subchapter I, Section 205

            (e) Labeling

            "[It shall be unlawful …] To sell or ship or deliver for sale or shipment, or otherwise introduce in interstate or foreign commerce, or to receive therein, or to remove from customs custody for consumption, any distilled spirits, wine, or malt beverages in bottles, unless such products are bottled, packaged, and labeled in conformity with such regulations..."

            So... Under para (e) the COLA approval process is only required if you're shipping or receiving beverages in interstate commerce or customs. Before I'd rely on my quick-and-dirty attention deprived and non-exhaustive research, I'd call TTB to confirm but it looks pretty clear that if you're staying local the TTB labeling regulations are not applicable to your containers.
            Kevin McGee

            Healdsburg Beer Company
            Sonoma County, California

            "Because this town sure didn't need another winery."

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            • #7
              That is what I told him today on the phone. Our labeling instructions here in VA are a pain and say that you have to include your approved TTB application... problem is that you do not need one and it does not say that anywhere in the instructions.

              Mike
              Mike Pensinger
              General Manager/Brewmaster
              Parkway Brewing Company
              Salem, VA

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              • #8
                be sure to check that your state does not require ttb approval. even though the feds don't require approval for in-state only distribution, some states like CO want it either way.

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                • #9
                  Next look at a Bud keg and see how little is actually necessary. Do note that most kegs have the GOVT WARNING stamped on them as well as the "Don't blow it up..." warning that at least CA requires.

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                  • #10
                    When we first opened we were only in-state and had to get TTB approval. The government warning needs to be affixed to the keg, either embossed or a sticker. The COLA online has made a process that used to take months able to be done in a few days, just make sure your fonts are all the correct size. Once you figure out 1 label use it as a basis for all the others, some breweries older labels wouldn't get approved now, trust me I had to redo one for a slight change, so I wouldn't use another breweries as a template.

                    Cheers.

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                    • #11
                      In state only...

                      We got some advice on labels for beer to be sold in state only from an attorney and guess what...he was wrong.

                      Rather plainly stated on the COLA apllication...there is a question regarding if product is to be sold solely in one state. If it is you are still required to get TTB approval as their standards for labeling still stand at state level. Once approved you must include on your label...'to be sold only in state of ___' fill in your state...

                      Don't trust attorneys to know TTB regs...go straight to the source.

                      Tash

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                      • #12
                        Even if you are only distributing in state, you still need the COLA approval from the TTB. Those labeling requirements apply in all states, no matter what additional requirements the states have. Until the new regs come out for labeling, one of the only areas where state regs win over the TTB ones is where the ABV is included or not. In addition to looking at the federal labeling regulations, also make sure you know the state's regulations as well - there may be additional requirements to the federal ones. The state requirements are usually not in the laws, but in the state's code of regulations. Most ABV boards are good about posting links to their laws.

                        And, before paying any lawyer for advice... always make sure he or she practices in the alcoholic beverage business - and that you will not be paying for him or her to be doing research you could do (and then get the answer wrong).

                        Good luck!

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                        • #13
                          Originally posted by Tash View Post
                          We got some advice on labels for beer to be sold in state only from an attorney and guess what...he was wrong.

                          Rather plainly stated on the COLA apllication...there is a question regarding if product is to be sold solely in one state. If it is you are still required to get TTB approval as their standards for labeling still stand at state level. Once approved you must include on your label...'to be sold only in state of ___' fill in your state...

                          Don't trust attorneys to know TTB regs...go straight to the source.

                          Tash
                          Tash you are painting with a pretty broad brush. Are you not lumping all lawyers together? That's like saying beer sucks, if Bud or some Bulgarian beer is lousy. You might want to consider calling somebody with specialization or experience in the particular field. Law is a pretty big beast and even most lawyers with experience only know narrow sectors well. Because there is so much to it, it's even harder for non-lawyers, or people with less experience.
                          Lehrman Beverage Law
                          www.bevlaw.com
                          202-449-3739

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                          • #14
                            Holy Thread resurrection Batman!
                            Mike Pensinger
                            General Manager/Brewmaster
                            Parkway Brewing Company
                            Salem, VA

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                            • #15
                              I'm actually curious about the weather or not TTB Label Approval is required if you're only distributing in-state. I've called the Labeling and Formula Division as well as emailed them. So, I will post their response once I receive it. I would like to note that in the Commonwealth of Kentucky, a TTB Label Approval is NOT required to distribute in-state.

                              If it comes out that it's not required, that would save us some time, however, I'm thinking why not go ahead and get a label approval just in-case? With the COLAS Online, as of now, it's taking them about 35 days to process label applications. Not terrible. Example:

                              Distributor: Hey! You make this very, very good Stout and we would love to distribute it in this State because none of the breweries we currently distribute brew this kind of Stout and the market here is crazy about it.

                              You (brewer): That would be awesome! But it looks like we have to get a TTB Label Approval first for that State. Our State didn't require it, so we skipped the headache. Let me get on that ASAP and find a label designer and get the design as fast as possible.

                              *45 days later*

                              Distributor: Hey again! It looks like X Brewery has released a Stout that is the same quality as yours. Looks like you'll have some hard competition in the market from a well-established brand. Good luck!
                              Mike Slone
                              Co-Founder, Head Brewer
                              23 Brewing Company
                              Instagram: @23brewingco - Facebook.com/23BrewingCompany

                              "Beer is the drink of men who think, who feel no fear nor fetter. Who do not drink to senseless sink, but drink to think the better" - Anonymous

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