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ATF/TTB question for the DRAFT ONLY micros...or anyone else for that matter.

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  • ATF/TTB question for the DRAFT ONLY micros...or anyone else for that matter.

    Maybe one of the DRAFT ONLY microbrewers out there has an answer to this question:

    I have a draft-only micro startup (no pub), and I was wondering if I need to do any kind of COLA stuff with the ATF/TTB guys. My contact there seems very green, and while I will ultimately follow his guidance, it's always nice to hear what requirements others are seeing in this area.

    Also, perhaps of note: distribution will not be outside of the state.

    I currently have the gov'nt warning on the kegs, and the name/address/website for the brewery too.

    Wondering how long it will take as well...

    Thanks guys.
    Scott

  • #2
    Draught question

    Here you go:

    Federal, state and local regulations governing draught beer should always be thoroughly investigated by the brewer prior to releasing product to the public. Below are some general guidelines to federal regulations however the reader is encouraged to consult the federal registry for complete information.

    The keg itself is to be permanently labeled with the brewer’s name. The place of production must be permanently marked on the keg, bung, tap cover or on a label securely affixed to each keg. For breweries with multiple production facilities, the place of production can be part of a list of all locations as long as it is not given less emphasis than any of the others. However if more than one location is shown on the keg, the brewer has to indicate the actual place of production by printing, coding or other markings on the bung, tap cover or a separate label. The coding system must allow a government official to determine where the keg was produced. The code must have a street address if the brewery has more than one operation in the same city. The regional compliance director has to be notified before using a coding system.

    Label approval is required if a label or tap cover is used. Labels or tap covers used must have Certificates of Label Approval (COLA). All alcoholic malt beverages must be marked, branded or labeled with the required information. No statement as to payment of internal revenue taxes may be shown.

    Alcoholic malt beverages must be labeled for the following:

    1. Brand Name.
    2. Class and type designation.
    3. Name and address of brewer (can be stamped or branded on container).
    4. Country of origin if imported.
    5. Name and address of importer (if applicable).
    6. Name and address of the packer in the case of malt beverages packed for the holder of a permit or a retailer.
    7. Net contents (stamped or branded on the container).
    8. Alcohol content (when required by state law).
    9. Health warning statement.

    Remember these are GENERAL guidelines and you really need to check with the government. Remember a tap handle constitutes a label and must be approved. So does any kind of neck ring or other decorations. If you have more questions, e-mail me at Bob@majesticpackaging.com.

    Bob August

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    • #3
      Thanks Bob,
      That's a bunch of great info. Did you lift it from a site I should take a closer look at, or did you author it from scratch?

      I didn't expect that Tap Handles required COLA approval, so thanks especially for that.

      Cheers,
      Scott

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      • #4
        Draught question

        Scott,

        It is an excerpt from a chapter I wrote for the new version of the Practical Brewer aimed at the craft brewer. Glad it was helpful. The book should be out soon and sold through the MBAA.

        Bob

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        • #5
          COLA

          Scott,

          Check out the TTB website, as well as your State Liquor Board. New York State, for example, requires that a COLA be submitted to them after TTB approval ($150 for each brand).

          Also, from what I can tell, the name of the brewery does not need to be permenantly displayed on the keg (i.e. embossed or etched). It should be marked on a collar or cap.
          Kelly Taylor
          Kelso Beer Company
          Brooklyn, NY
          email: kelly@kelsobeer.com

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