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Thread: California Growler Labeling???

  1. #1
    Join Date
    Oct 2002
    Location
    usa
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    110

    California Growler Labeling???

    In California do brewpubs have to state alcohol content on their growlers? This would of course have to be brand specific as well. Anything over 5.7% abv. Just curious to see what folks are doing.

    Tash

  2. #2
    Join Date
    Nov 2003
    Location
    Napa CA
    Posts
    65

    Growler labels

    We use a water resistant address label that has our location, a space for the product name and abv, and of course the gov't warning. i insist that every growler filled gets one even if the abv is under 6.0%
    We also do not fill other breweries growlers, get a few complaints that customers don't want 200 growlers laying around, but we are just trying to cover our butts.
    Nick
    Nicholas Campbell

  3. #3
    Join Date
    Nov 2005
    Posts
    59
    You may already know this, but growler labels need to be approved by the federal TTB. There may be additional CA or local laws.

    After a quick search on TTB for "growler", it says the "Alcoholic Beverage Labeling Act (ABLA) of 1998 applies" and the mandatory information includes brewery name, place of production, net contents, and government warning label.

    As a person who runs brewpubs, I'd put in text for Beer Style, Alcohol Content, and Date - as these things are good for the guest, probably the legal thing to do, or both. I also used to attach a little card with an history of the word "growler", attached with a piece of twine, because I'm a nice guy. Never fill someone else's growler - it does not have the correct labels, and is most likely illegal.


    Cheers,
    --Jake Tringali

  4. #4
    Join Date
    Oct 2002
    Location
    usa
    Posts
    110

    California specific labeling of growlers

    Above and beyond the TTB the State of California has rather specific language about the product going into any size bottle. There is not anything particular that I can find on how it relates to growlers. Apparently putting a small 'sticker/decal/label' on the bottle with alcohol details is the norm. Or at least that is what is happening around here.

    Tash

  5. #5
    Join Date
    Jan 2006
    Location
    Ponderay, Idaho
    Posts
    229

    Growler labels

    this is from the TTB web site if you pre fill growlers its a bottle and needs label approval, if you fill it at time of sale it a large glass and does not this is a federal guidline of course state regs may be different

    "A growler is either a bottle or a large glass. The distinction is solely dependent on the manner in which the brewer fills the container.

    When is a growler a “bottle?”
    A growler is a bottle when the brewer fills the container in advance of sale. The brewer may fill the growler prior to removal, on the brewery premises, or after tax determination on the brewpub premises.

    When is a growler a “large glass?”
    A growler is a large glass when a consumer uses the container to make a purchase and the brewer then fills the container. Consumers may furnish their own growler or may purchase it from the brewer.”



    Fred Colby
    Laughing Dog Brewing

  6. #6
    Join Date
    Nov 2005
    Posts
    59

    California Beer Growlers

    I dropped a message to the CA ABC to see if they would give an official answer. Once I get a message back, I'll post it - if they don't post directly here first.

    Cheers,
    --Jake Tringali

  7. #7
    Join Date
    Nov 2005
    Posts
    59

    CA ABC Reply

    Here's an answer from the CA ABC:

    Cheers,
    --Jake Tringali

    ---

    "Dear Mr. Tringali:

    Section 25200 of the ABC Act and Rule 130 of the California Code of Regulations address the issue of beer labeling. Form ABC-412 (Application for Label Approval) has instructions that further explain our labeling requirements. You can access both the ABC Act and the Code of Regulations on our Web site (www.abc.ca.gov) under “Resources” on the right-side of the home page. Form ABC-412 can be accessed under the “Forms” link under “Resources.”

    Growlers, like any other type of beer container, must have a label with certain mandatory information. This assumes, of course, that the growler is sold “to go,” either to the consumer/purchaser or for resale to wholesalers or retailers.

    Section 25204 mandates an alcoholic content statement for beer if the product contains more than 5.7% alcohol by volume. Some beer manufacturers list alcoholic content on all their products. This is acceptable but not required.

    Sincerely,
    David Wright
    Business Practices Unit"

  8. #8
    Join Date
    Oct 2002
    Location
    usa
    Posts
    110

    Exclamation Just a final thought...

    Is it just me or do most brewpubs in CA. fail to follow this rule/law? I've been to numerous brewpubs in the state and most have a generic label and then 'maybe' a sticker for ABV. This can't possibly be following the letter of the law can it?

    Tash

  9. #9
    Join Date
    Nov 2005
    Posts
    59

    Breakin' the law, breakin' the law

    This may shock you!: Yes, many brewpubs break the law. Here's a partial list:
    - Selling growlers without proper labeling
    - Selling growlers when it is not permitted with your Conditional Use Permit (depends on your location)
    - Refilling other people's growlers (ones without the proper label)
    - Selling kegs when it is not permitted with the CUP and/or license
    - Selling kegs at different prices for different people (I think that's illegal, not sure)
    - Having Happy Hour (discounted alcohol) when it is not permitted with your CUP
    - Selling kegs without filling out the proper paperwork

    As far as I've seen, there is virtually no enforcement of these laws. I do know of one brewpub that had to stop selling growlers because it wasn't within its legal rights to do so.

    It puts more pressure on us nice guys who play by the rules, but I guess that's a choice in life we have to make.

    Cheers,
    --Jake Tringali

  10. #10
    Join Date
    Jun 2003
    Location
    Louisville, KY
    Posts
    993

    Instant Karma's gonna get you!

    Good point Jake. In my travels I have seen many violations of many state laws. When asked most of the management would say "Oh well everyone does it". Kind of hard to play on a level field.



    Quote Originally Posted by CallerFromLA
    This may shock you!: Yes, many brewpubs break the law. Here's a partial list:
    - Selling growlers without proper labeling
    - Selling growlers when it is not permitted with your Conditional Use Permit (depends on your location)
    - Refilling other people's growlers (ones without the proper label)
    - Selling kegs when it is not permitted with the CUP and/or license
    - Selling kegs at different prices for different people (I think that's illegal, not sure)
    - Having Happy Hour (discounted alcohol) when it is not permitted with your CUP
    - Selling kegs without filling out the proper paperwork

    As far as I've seen, there is virtually no enforcement of these laws. I do know of one brewpub that had to stop selling growlers because it wasn't within its legal rights to do so.

    It puts more pressure on us nice guys who play by the rules, but I guess that's a choice in life we have to make.

    Cheers,
    --Jake Tringali
    Last edited by beertje46; 12-04-2006 at 01:37 PM. Reason: content
    Cheers & I'm out!
    David R. Pierce
    NABC & Bank Street Brewhouse
    POB 343
    New Albany, IN 47151

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