COLAs and the Tax Trade Bureau

While most folks think of brown fizzy drinks when they hear the word “cola”, those in the wine industry think immediately of the Alcohol and Tobacco Tax Trade Bureau (“TTB”). A Certificate of Label Approval, or “COLA” as it is known in the industry, is required by TTB for any wine prior to the wine being released into the stream of commerce.

    The label on a bottle of wine is used by a winery to attract potential buyers, and is used by them as a tool in determining whether to buy that wine. Because wine labels are such an important piece of the wine buying and selling experience, they are very closely regulated by TTB.

    Wine labels must be pre-approved by TTB. This occurs through a process that involves submitting a proposed wine label to TTB, followed by TTB’s detailed review of the proposed label, and ending either with the issuance of a COLA or the return of the proposed label with the basis or bases of TTB’s rejection. TTB realizes that consumers rely heavily on wine labels, and takes very seriously the job of ensuring the public is protected from claims or descriptions on wine labels that mislead the wine-buying public into purchasing a product that does not comport with its label.

    Some information must be included on a wine label, while other information may be included at the winery’s discretion. There are also requirements as to location of certain information on the label. For example, the brand label must include the brand name, the class and type of wine, the alcohol content and possibly the Appellation of Origin. Other required information, which can be anywhere on the bottle (i.e., on the neck, side or back) includes the bottler, the location of the bottler, Health Warning Statement, sulfite declaration and net contents. All bottles must have a brand name and must identify the wine’s class, type or designation. There are nine classes of wine (created by TTB), including grape wine and aperitif. Wine types are those such as red table wine or dessert wine. A designation can be a varietal (e.g., Cabernet) or fanciful (proprietary).

    All wines must have a brand name. There are few restrictions on brand names for wines, though again, TTB looks closely for misleading descriptions. If a brand name is descriptive of the wine itself, it must be accurate – i.e., if the brand name is “Paso Robles Merlot”, the wine must be from grapes grown in Paso Robles and be a merlot. If the brand name includes a specific vineyard or farm, 95 percent of the contents must be from that vineyard or farm. Where there is no actual brand name, the bottler’s name will be used as a brand name.

Jeannie D. Goshgarian

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