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California Specific labeling requirements - ABC and TTB

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  • California Specific labeling requirements - ABC and TTB

    Trying the navigate the very confusing laws around labeling between TTB and ABC.

    I am a small brewer in CA, only selling within my state at this time. We are designing our keg collars and our growler labels right now.

    I've figured out that TTB considers a growler filled in front of the customer a 'large glass' and therefore do not need to approve my growler label (nor does the Government health warning need to be included). However, given there is a chance a growler could be pre-filled before sale, it is recommended to have the health warning on the label, so we are covered. So we will include the health warning. But now the question begs... say a growler was pre-filled some day... and now it's considered a 'bottle'... should we just go ahead and submit our growler label to TTB (via COLA) for approval anyway? As for ABC: my understanding is that they do consider a growler a sealed vessel, but they do not require us to submit the whole label design to them, but rather just fill out form ABC412 to register each 'brand' (beer name/style) each time we come up with a new beer. They do not seem to request the label be submitted. They do however point to the TTB regulations:

    (a) A package or sealed container of beer shall not be sold in this
    state without having a label affixed to such package or container.
    The label shall meet the requirements of federal malt beverage
    labeling regulations contained in Parts 7 and 16 of Title 27 of the
    Code of Federal Regulations,
    regardless of whether the label is
    subject to approval by the federal Alcohol and Tobacco Tax and
    Trade Bureau or any successor agency.


    Part 16 pertains to the government health warning (I get it).

    Part 7 says:

    7.22 Mandatory label information.
    There shall be stated:
    (a) On the brand label:
    (1) Brand name, in accordance with § 7.23.
    (2) Class, in accordance with § 7.24.
    (3) Name and address (except when branded or burned in the container) in accordance with § 7.25, except as provided in paragraph (b) of this section.
    (4) Net contents (except when blown, branded, or burned, in the container) in accordance with § 7.27.
    (5) Alcohol content in accordance with § 7.71, for malt beverages that contain any alcohol derived from added flavors or other added nonbeverage ingredients (other than hops extract) containing alcohol.
    (b) On the brand label or on a separate label (back or front):
    (1) In the case of imported malt beverages, name and address of importer in accordance with § 7.25.
    (2) In the case of malt beverages bottled or packed for the holder of a permit or a retailer, the name and address of the bottler or packer, in accordance with § 7.25.
    (3) Alcoholic content, when required by State law, in accordance with § 7.71.......

    And some other stuff about additives that doesn't concern us.

    For keg collars, all the same questions beg, except a keg is definitely a sealed container in both the eyes of the ABC and the TTB. Thus the keg collar will have the health warning, as well as brewery name, address, beer style, ABV, etc. Again, ABC will want us to register each 'brand' (beer name/style), but do not need to see the keg collar per se? TTB, however, will want to see the keg collar, yes? Along with Form 5100.31 (label approval). In addition, my keg collar does not have names of beer pre-printed with check boxes, but rather a blank section in which the beer name gets inserted each and every time. Will I need to hand write each beer name in and submit as a seperate keg collar or growler label for each beer?

    Tell me if I've misunderstood anything!

  • #2
    Following

    I am following this as I am in the same position now and am looking for similar answers regarding the keg collars, and growlers.

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    • #3
      I'm following this as well, would appreciate some answers to the questions. Thanks!

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