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Thread: Growler Labels

  1. #1
    Join Date
    Oct 2011
    Stonington, CT, USA

    Growler Labels

    It's about time to place our glassware order. We're a CT based manufacturer with a tasting room that plans on offering regular growler filling hours. We will not be pre filling any growlers. Do I need to submit our growler labels to COLAS Online and does anyone know if CT requires us to submit our non pre fill growler labels for approval? Thanks!
    Aaren M. Simoncini
    The Beer'd Brewing Co. LLC
    22 Bayview Ave. Unit # 15
    Stonington, CT. 06378

  2. #2
    Join Date
    Oct 2003
    East Hartford, CT

    I think you just need to have the brewery name, address, and government warning on the bottle. I KNOW you need the government warning. Give TTB a shout. They'll tell you exactly what you need. It will save aggravation in the long run.

  3. #3
    Join Date
    Nov 2011
    Chestertown, Maryland
    According to the TTB web site, they treat growlers that are not filled prior to purchase as a "glass."

    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.

    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 ABLA does not apply to glasses or containers a brewer uses to serve beer at the brewpub. These containers do not meet the definition for a sealed container in which an alcohol beverage is offered for sale to the public.
    However, 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.
    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.

    What are the requirements for growlers that are “glasses?”
    When the brewer fills a growler at the tap at the brewpub, and not in advance of sale, we consider the growler as a large glass sold at retail. These growlers are not subject to Federal labeling requirements. Some States consider this bottling activity and regulate accordingly. Brewers should check with State authorities.

  4. #4
    Join Date
    Mar 2006
    Ex-Germany / California
    I am sure that if you talk to the people who will be selling you growlers, they will know what you will need too. It's their business. Try

  5. #5
    Join Date
    Jul 2010

    Glass versus bottle

    From my understanding, I'm not a lawyer but having been through this recently:

    - If the growler is not filled prior to the customer purchase, the growler is a glass and doesn't require TTB approval
    - If the growler is filled prior to the customer purchase, the growler is a bottle and requires approval.

    To give us the flexibility to pre-fill in the future if we want to, and to be safe, we had the growler labels approved by the TTB.

    You should check your state requirements to make sure that there are no additional requirements there if you don't go for TTB approval.

    Adam Robbings
    Reuben's Brews

  6. #6
    Join Date
    Oct 2007
    Lexington VA

    Might be worth the effort to do COLA

    We fill to order and didn't need to do TTB-COLA but when we went to have VA-ABC approve our labels ($30 a label), primarily for tax purposes, it made it a longer process since we didn't have a TTB approval number to go with our application. Now that we are distributing and have to do TTB-COLA we just do the keg collar and send that approval # to the state, and it saves time and we can skip the state growler label approval issues and just pay VA-ABC.
    Plus if you make beer with other ingredients you have to do the COLA with a statement of process for TTB. The online process for COLA's is really quite easy, once you figure it out.

    Bill Hamilton
    The Brewer/Co-Owner
    Blue Lab Brewing Co.
    Lexington VA

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