Keg Labeling Requirements

[NigeltheBold]

I've looked on the TTB website and it's a bit confusing about what needs to be displayed on kegs.

One part says that you need the brewery name and location permanently displayed on the keg. Is this what people are doing with keg tape/keg wraps?

Does every keg also need a collar with the type of beer, net contents, alcohol percentage, government warning, etc? What else am I missing?

Also, does the collar need to be approved by the TTB if we're only distributing in-state?

I could contact the TTB, but they usually just refer me back to their confusing website.

[ChesterBrew]

What are the requirements for the government warning label?
The Alcoholic Beverage Labeling Act (ABLA) of 1998 applies to sealed containers the brewer offers for sale to consumers... the law applies to any keg or serving tank from which the brewer dispenses beer to containers. The brewer must apply a government warning label to the keg or tank. The brewer must comply with 27 CFR Part 16 regardless of whether the public has view of the keg or tank.

http://www.ecfr.gov/cgi-bin/text-idx?tpl=/ecfrbrowse/Title27/27cfr16_main_02.tpl

The statement must comply with these conditions.

It must be legible under ordinary conditions, and on a contrasting background.
The words “GOVERNMENT WARNING” must be in capital letters and bold type. The rest of the statement may not appear in bold type.
The maximum number of characters per inch of the warning statement is 25. All characters, including both upper and lower case, must be a minimum 2 millimeters in size.

[NigeltheBold]

So that covers the government warning, which must go on every keg. But that doesn't fully answer my question. What else needs to go on the keg/collar?

I'm thinking we'll get some tape with our brewery name and location on it. But now the question is, what needs to go on the collar other than the government warning? Obviously the name of the beer... but what else?

[ChesterBrew]

Yankee Schooner carries generic collars and will also create custom ones... they have images of each on their site. Hopefully this helps...

http://yankeeschooner.com/Keg%20Collars%20%2526%20Keg%20Caps

(right-click and select the image to view it at a higher resolution)

[Brandjes]

Here is the scanned image I provided for COLA approval. This was approved - no issues. The collar is a generic one from Yankee Schooner. Avery address labels for style and company info. You have to submit with the style/name checked for each style if doing a check box like mine. Scan the image in photo setting so that the scanned image fills the space with no borders or crop the image right to the edge of the collar. The on line COLA form is pretty straight forward. A Keg collar is considered the BRAND/FRONT label.

[NigeltheBold]

Thanks to both of you, this is very helpful!

[Braxtol]

I am in the process of applying and I have heard that TTB requires adhesive on the back of the keg collars so that it sticks to the keg. Is this true or a bunch of hoo-ha?

[jebzter]

Remember that if you are only selling within your state, the ttb doesnt need to approve your label. And dont overlook what your state requirements may be.

[Bainbridge]

Remember that if you are only selling within your state, the ttb doesnt need to approve your label. And dont overlook what your state requirements may be.

Correct, sort of. Many states turf it off to the feds with state laws requiring federal label approval. So, as mentioned, don't overlook your state's laws.

I've never seen any requirement that collars have adhesive on the back. Presumably it's some kind of misinterpretation of a word in the law like 'affixed' or 'securely labelled'. So long as your collars are tight enough around the spear to stay on, that's pretty much industry standard.

[MACowley]

Remember that if you are only selling within your state, the ttb doesnt need to approve your label. And dont overlook what your state requirements may be.

Can you point me to the page on the TTB site that states this??

Cheers

[ChuckD]

Keg collar

I am a small brewery (3bbl) and found that if your not pushing through a ton of keg distribution it's hard to justify a custom manufactured keg collar. They typically come in packs of 500 or so. If you have a contact with your state's department of alcohol they should tell you what is required for state and fed. We ended up purchasing minimum order of blank keg caps (a cap that fits over the sankey top ring) then going to the Avery print site and designing a label for their 22836 label. Buy the paper and print what you need. Note, tear off the outside ring prior to printing or it will not align.
In my state we need:
The govt warning.
"This product contains malt beverage"
Date (which is Date: _______) where I write in the date
address
company logo
keg size (I created 2 check boxes, one for 15.5G and one for 5.25G, which are the only two we carry)
an open space to write the registered beer name in

This is pretty labor intensive if your pushing a lot of kegs but manageable if your small. Try to keep most sales in house. You only get 9 to a sheet so it doesn't take long where a bulk purchase pays for itself.

-Cheers

[ryanriip]

Are you planning to sell your kegs across state line?

Per my attorney Candace Moon, here in CA the keg collar needs to get approved by the ABC like a normal label and it only needs an ABC approval if you do not plan on selling or taking your beer out of the state. (Ca laws).

I asked her about labeling on side of keg and she stated that's just for your protection and hopeful return of your property or if you plan on selling kegs to consumers(non retailers) aka as keg tags. Keg tags are not required for sale to retailers though. She gave me this printer for the collars. http://sm-printing.com/.

[MACowley]

Are you planning to sell your kegs across state line?

Per my attorney Candace Moon, here in CA the keg collar needs to get approved by the ABC like a normal label and it only needs an ABC approval if you do not plan on selling or taking your beer out of the state. (Ca laws).

I asked her about labeling on side of keg and she stated that's just for your protection and hopeful return of your property or if you plan on selling kegs to consumers(non retailers) aka as keg tags. Keg tags are not required for sale to retailers though. She gave me this printer for the collars. http://sm-printing.com/.

Actually, we want to brew beer for an upcoming event, which we are donating beer to.....so, it will not leave the state. I guess technically we are selling it to the distributor, then they are giving it to the event.

[DS-Mike]

Like most have said, the TTB does not require approval if it is only sold within your state but many states require TTB approval in order to register a brand. Others may require additional information. From my experience with the TTB you need the following on any keg collar.

- Brewery name and location. This can simply be the brewery name, city and state. The full street address is not needed.
- Government Warning. This has been covered above but just to recap the statement must be full and complete and the text GOVERNMENT WARNING must be all caps and bold.
- Contents of the keg. You can simply have multiple options with check boxes.
- Brand name and description. This is the name of the beer and it's required descriptor like Ale Brewed with (Insert Ingredients) or Ale with (Insert Ingredients) Added. There is actually a difference in how those and it is dependent on when the ingredients are added. Prior to fermentation it is "Brewed with." After fermentation it is "with (items) Added."

Alc./Vol is not required by the TTB but I know some states do require it. Having the pressure of contents statement is not required by the TTB either but it should be on keg collars.