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View Full Version : stupid Q about TTB cola approval -- when do you have to submit a formula?



powwowwow
11-04-2013, 09:03 PM
If I put a class designation such as "ale brewed with honey" or "ale brewed with spices" or "ale brewed with rose flowers" or whatever, and I don't put an ingredients list on the bottle, do I still have to submit a formula for their approval? I don't want to have to submit a formula because the TTB takes forever, and then they're liable to give me a stupid class designation like "malt beverage brewed with bla bla bla".

beejay
11-05-2013, 02:47 AM
Any time you are using other than malt, hops, sugar then you have to put a formula in. Whatever designation they give you "ale brewed with x ingredients" has to be put on the bottle. We usually just put designations in smallish print off to the side of our artwork and it satisfies them. It doesnt have to be in big bold letters in the middle of your label or anything.

powwowwow
01-17-2014, 11:20 AM
Does a barrel aged version of a pre-existing beer require a separate COLA approval? or can you use the same label but just add the words "aged in red wine barrels" to the label?

powwowwow
01-17-2014, 11:34 AM
Does a barrel aged version of a pre-existing beer require a separate COLA approval? or can you use the same label but just add the words "aged in red wine barrels" to the label?

beejay
01-17-2014, 01:44 PM
Any change to the label, with some minor exceptions such as changes in ABV and volume, require a new label approval. So any added text, including "aged in..." will require a new label approval. You will also need a formula approval for anything aged in a barrel that previously held anything. If it is a brand new oak barrel then you do not need a formula approval, unless the beer itself ingredients requiring formula approval.

beejay
01-17-2014, 01:50 PM
Here is some info on what can be changed

http://www.ttb.gov/labeling/allowable_revisions.shtml

Not sure, but this may apply...

"15. Delete or change an optional age statement, including a barrel aging statement, for wine and malt beverage labels." -Which is allowed

Seems like you can't add a statement of barrel ageing but just change it. In any case, when you apply for a COLA for a beer requiring formula approval, you have to submit the formula ID any way, so a new barrel aged beer would require this addition, thus a new COLA I suppose.

powwowwow
01-18-2014, 10:20 AM
thanks beejay.

mashpaddled
01-19-2014, 10:22 AM
Here is some info on what can be changed

http://www.ttb.gov/labeling/allowable_revisions.shtml

...

If you already have label approval on the beer you could remove or change the barrel aging statement but you cannot add the optional statement regarding barrel aging without obtaining a new COLA. In the link provided you can see there is a difference between allowable revisions without a new COLA that state "delete or change" versus "add, delete, or change".

You would not need to submit a new formula approval for an existing beer that is going to be barrel aged if the beer is going into fresh, unused barrels. You still need to get a COLA to add the statement to the label. (You could barrel aged the beer in new barrels and not put the statement on the label and not obtain a COLA but why would you not want to identify the beer as barrel aged?)

An existing beer going into wine or spirit barrels would require formula approval and a COLA for the barrel aged version.