Once TTB approves your label, you can make a surprising number of changes without filing a new Certificate of Label Approval. Knowing which changes are allowable saves weeks of review time, and knowing which ones are not saves you from selling non-compliant product. Use the checker to get a fast read, then keep the reference handy.
A COLA (Certificate of Label Approval, TTB Form 5100.31) is TTB's sign-off on your label before you bottle and remove product. Getting a new one takes time, and in a backlog it can take a lot of time. The good news: TTB maintains a list of roughly 40+ allowable revisions you can make to an already-approved label without submitting a new COLA.
The catch is that every allowable change carries conditions. The revision still has to comply with the labeling regulations in 27 CFR parts 4, 5, 7, and 16, and with the specific conditions in the "Comments" column of TTB's official chart. "Allowable" does not mean "anything goes", it means "allowable, if you meet the conditions."
This page gives you a fast gut-check and the common cases. For the authoritative, complete list, always confirm against TTB's official chart on the COLA form and their sample label generator, both linked below.
Pick your product and the change you want to make for a quick read. This is a guide, not a determination.
Common examples on each side. These are typical cases, every allowable change still carries conditions in TTB's official chart, so confirm before you rely on it.
A common misconception is that you can freely add non-mandatory language or graphics to an approved label. Generally, you cannot. TTB allows you to delete non-mandatory information freely, but adding new wording, phrases, or artwork usually requires a new COLA, unless it is one of the specifically authorized additions (like certain serving instructions). Deleting is easy; adding is where producers get tripped up.
Common questions about COLAs and which label changes need a new certificate of label approval.
A COLA is a Certificate of Label Approval (TTB Form 5100.31), TTB's approval of your alcohol beverage label before you bottle and remove the product. It certifies that the label complies with federal labeling regulations. You generally need an approved COLA (or a valid exemption) before selling a labeled product in interstate commerce.
Often, yes. TTB maintains a list of roughly 40 allowable revisions you can make to an already-approved label without filing a new COLA, such as changing a website, phone number, or ZIP code, adding or removing awards, or deleting non-mandatory information. Each allowable change carries conditions, and the revision still has to comply with the labeling regulations. Always confirm your specific change against TTB's official chart.
Usually not. This is a common and costly misconception. TTB generally lets you delete non-mandatory information freely, but adding new wording, phrases, or artwork typically requires a new COLA, unless it is one of the specifically authorized additions like certain serving instructions ('Serve Chilled,' 'Shake Well'). Deleting is easy; adding is where producers get tripped up.
Changes that alter the identity of the product generally require a new COLA: changing the brand name, changing the class or type (for example, vodka to gin), changing the stated alcohol content beyond the permitted tolerance, changing a wine's appellation of origin or varietal, and adding new non-mandatory wording or graphics. When in doubt, treat an identity-changing revision as needing a new COLA.
It varies with TTB's current workload, and during backlogs or government shutdowns it can take considerably longer. That is exactly why it is worth checking the allowable revisions list first, if your change qualifies as an allowable revision, you can make it without waiting in the COLA queue at all.
The authoritative list is on pages 3 and 4 of the COLA form (TTB F 5100.31), and TTB also offers an online Allowable Changes Sample Label Generator that illustrates examples. Any revision must comply with 27 CFR parts 4, 5, 7, and 16 and the conditions in the form's Comments column. This page summarizes the common cases; always confirm the specifics against TTB's official sources.