TTB Beer Label Requirements: 8 Elements You Need on Craft Beer Labels

The process of putting together a craft beer label can be as complex as brewing the beverage itself. Your beer labels need to not only capture the quality and personality of your products, but also meet any mandatory Alcohol and Tobacco Tax and Trade Bureau (TTB) label requirements. These requirements play a pivotal role in TTB labeling approval before your product can be sold to consumers. Let’s break down what your beers need to maintain TTB label compliance.

The 8 TTB Requirements for Beer Labels

There are eight key elements that must be included on any beer label. Some of these elements are mandatory for every malt beverage, while others may apply to only certain situations. These label elements are:

  • Brand name
  • Class and type designation
  • Name and address
  • Net contents
  • Alcohol content
  • Disclosures for specific ingredients
  • Health warning statement
  • Country of origin

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Each of these elements has their own specific labeling guidelines. One typical labeling regulation is to meet specific placement and legibility rules. Each element should meet the following beer label requirements unless specifically noted below.

  • Appear on the front of your container.
  • Use a minimum type size of 2 mm for containers larger than ½ pint or 1 mm for containers of ½ pint or less.
  • Appear on a contrasting background.
  • Appear separate and apart from or be substantially more conspicuous than descriptive or explanatory information.

In addition to placement and legibility, there are several other standards you need to follow for each label element. Let’s break down each of these elements and what you need to know about their TTB label requirements.

A trio of beer bottle labels with net contents and other TTB label requirements.

Brand name

The first piece of information that any beer label should have is a brand name. This piece of information is typically the most prominent piece of information on your label and should reflect the name that you use to market your beer. If your beer doesn’t happen to be sold under a brand name, the name of the bottler or packer, importer is used as a de facto brand name instead.

In addition, your brand name must not be misleading. By TTB standards, that means that your brand name should describe “the age, origin, identity, or other characteristics of the malt beverage.” There are a few exceptions to this rule:

  • The brand name accurately describes the malt beverage and doesn’t create an erroneous impression about your malt beverage.
  • Your label includes a statement that dispels any erroneous impression created by the brand name.
  • Your brand name is qualified with the word “BRAND.”

Class and type designation

Every beer label needs to clearly display the specific identity of what’s contained in the can or bottle. Simply put, it needs to tell consumers what type of malt beverage you made.

These designations are based on characteristics generally attributed to the particular class or type of malt beverage. These designations can range from something as general as “malt beverage” to a very specific type of beer like “imperial stout.” For definitions and general descriptions of different classes and types of malt beverages, please refer to Chapter 4 of the TTB’s Beverage Alcohol Manual.

Name and address of producer/bottler or packer

The TTB mandates that every malt beverage label includes both the name and address of the entity that produces, bottles, packs, or imports your products. Domestic malt beverages may include an appropriate explanatory phrase before the name, while imported products must add some more detail). These can include the following:

  • For domestic brewers (optional)
    • “BREWED AND BOTTLED/PACKED BY”
    • “BREWED BY”
    • “BOTTLED/PACKED BY”
  • • For importers (mandatory)
    • “IMPORTED BY”
    • “SOLE AGENT”
    • “SOLE U.S. AGENT”

For the name, you may use your company name, corporate name, or trade name. The key here is that your name must be identical to what is displayed on either your brewer’s notice for domestic malt beverages or basic permit for imported malt beverages.

As for the address, domestic products should include either the city and state where your malt beverage is bottled or packed or a principal place of business. Imported products are limited to their principal place of business. If you choose to use a principal place of business as a domestic malt beverage, that location must meet the following requirements.

  • The principal place of business address must be a location where production/bottling or packing operations occur.
  • The actual location (address) where the malt beverage is produced/bottled or packed must be indicated by printing, coding, or other markings on the label or container.
  • Prior to use, the brewer must file a notice explaining the coding system with the TTB’s National Revenue Center.

As with many other label elements, the name and address should be included on the front of your container. However, you also have the option to burn or brand these details somewhere visible on your containers for domestic malt beverages.

Net contents

While there are no standards of fill for malt beverages, the TTB does have requirements for the way you list net contents. Every container must list net contents in American measurements, but you may also include metric measurements as well. The TTB also has specific standards for how these measurements are presented.

  • Containers with less than 1 pint – the net contents must be shown in fluid ounces or fractions of a pint.
  • Containers with an exact number of net contents (ex. 1 pint, 1 quart, or 1 gallon) – the net contents must be shown exactly that way.
  • Containers with more than 1 pint but less than 1 quart – the net contents must be shown in pints and fluid ounces or fractions of a quart.
  • Containers with more than 1 quart but less than 1 gallon – the net contents must be shown in quarts, pints, and fluid ounces or fractions of a gallon.
  • Containers with more than 1 gallon – the net contents must be shown in gallons and fractions thereof.

As with names and addresses, you also have the option to burn or brand net contents into the container itself. If not, they must be placed on the front of the container’s label.

Alcohol content

Unlike many of the other elements, statements of alcohol content are optional unless your state’s law either mandates or prohibits this action. Whether these statements are required label elements or added optionally, the TTB does set specific standards for how alcohol content is presented.

Unless your state’s laws set a different standard, statement of alcohol should be expressed in percent by volume. The exact alcohol content must be listed to the nearest 0.1 percent for any malt beverages with 0.5 percent alcohol by volume or more (with a tolerance of plus or minus 0.3 percent). If your product has less than .05 percent alcohol by volume, your statement should be accurate to the nearest 0.01 percent. These statements should also be presented in one of the following formats.

  • “ALCOHOL (ALC) __% BY VOLUME (VOL)”
  • “ALCOHOL (ALC) BY VOLUME (VOL) __%”
  • “ __% ALCOHOL (ALC) BY VOLUME (VOL)”
  • “ __% ALCOHOL (ALC)/VOLUME (VOL)”

In terms of legibility and placement, the alcohol statement has a few additional standards to note. Unlike other label elements, the alcohol statement can be placed on the front, back, or side of your container. The entirety of your alcohol statement should be in prominent coloring and use the same kind and size of lettering. The type size also depends on the net contents of your container.

  • Minimum 2 mm type for containers larger than ½ pint
  • Minimum 1 mm type for containers of ½ pint or less
  • Maximum 3 mm type for containers of 40 fl. oz. or less
  • Maximum 4 mm type for containers larger than 40 fl. oz.

Disclosures for specific ingredients

Beer labels can require disclosures for certain ingredients if they appear in your malt beverage. Each ingredient requires a separate statement to make its presence clear to any consumers. These are the four different ingredients and their required statements:

  • FD&C Yellow No. 5 – “Contains FD&C Yellow #5”
  • Saccharin – “Use of this product may be hazardous to your health. This product contains saccharin which has been determined to cause cancer in laboratory animals.”
  • Sulfite (if 10 or more parts per million sulfur dioxide) – “Contains sulfites” or “Contains (a) sulfiting agent(s)”
  • Aspartame – “PHENYLKETONURICS: CONTAINS PHENYLALANINE.” (note: this disclosure must be in all capital letters)

A beer can with a prominent government warning.

Health warning statement

Every beer label should include a health warning statement if the malt beverage in question contains at least 0.5 percent alcohol by volume. The statement in question must appear as a continuous paragraph and start with the words “GOVERNMENT WARNING” in bold, capital letters. The statement in full should appear as follows.

  • GOVERNMENT WARNING: (1) According to the Surgeon General, women should not drink alcoholic beverages during pregnancy because of the risk of birth defects. (2) Consumption of alcoholic beverages impairs your ability to drive a car or operate machinery, and may cause health problems.

This statement may appear on the front, side, or back of the container. The statement’s type size and maximum number of characters per inch depends on the net contents of the container.

  • Minimum 3 mm for containers larger than 3 liters (101 fl. oz.)
    • No more than 12 characters per inch
  • Minimum 2 mm for containers larger than 237 ml (8 fl. oz.) to 3 liters (101 fl. oz.)
    • No more than 25 characters per inch
  • Minimum 1 mm for containers of 237 ml (8 fl. oz.) or less
    • No more than 40 characters per inch

Country of origin

If your malt beverage is imported, your label must include some form of statement indicating its country of origin. There are four formats you can use for this statement:

  • “PRODUCT/PRODUCE OF [name of country]”
  • “PRODUCED/BREWED IN” or “PRODUCED/BREWED AND BOTTLED OR PACKED IN [name of country]”
  • “PRODUCED/BREWED BY” or “PRODUCED/BREWED AND BOTTLED OR PACKED BY [name of brewer and/or both brewer and bottler/packer along with either the country or both city and country]”
  • “___________ ALE” (Fill in blank with name of country in which ale was produced/brewed), i.e., name of country with class and/or class and type designation

Unlike other beer label elements, the country of origin does not need to follow any specific legibility and type size requirements. Your statement may also appear anywhere on the front, side, or back of your container.

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There’s a whole lot of information that the TTB requires for beer labels, but that doesn’t mean that these elements need to hold back your design. Fortunately, the right label printing company can turn your initial design into a stunning final product.

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3 Reasons Why the TTB Turned Down Your COLA (and How to Avoid Them)

In the beverage world, a label denial can prove quite problematic for any new beer, wine, or spirit. No matter which or the three products your company makes, the Alcohol and Tobacco Tax and Trade Bureau (TTB) requires you to apply for a Certificate of Label Approval/Exemption (COLA) before that specific product ever hits the market.

Of course, this requirement means you need to play by the TTB’s rules. This process applies to your initial application for a COLA and if you make future changes to your labels – all it takes is a single TTB audit to pull your products from shelves. There is a lot of information required on wine labels and other alcoholic packaging, so the TTB will pay close attention to make sure everything is in the right place.

TTB regulations can seem a bit overwhelming, but a little guidance can help you properly prep your beer, wine, and spirits labels. It also helps to know about a few particular COLA pain points. Here are three common reasons why the TTB may turn down your COLA.

The Government Warning Statement isn’t Right

One of the easiest mistakes to make involves the mandated government warning. Any product that contains at least 0.5 percent alcohol by volume requires a government warning on its label. That warning reads as follows.

  • GOVERNMENT WARNING: (1) According to the Surgeon General, women should not drink alcoholic beverages during pregnancy because of the risk of birth defects. (2) Consumption of alcoholic beverages impairs your ability to drive a car or operate machinery, and may cause health problems.

Seems simple right? The tricky part is that the TTB is very particular about the presentation of this warning. The warning should read exactly as it does above, including how the first two words are bolded and capitalized. Even a missing or misplaced comma can result in a failed COLA.

In addition, the TTB has specific format requirements for the warning. First, the warning itself must be “readily legible under ordinary conditions” and appear in a contrasting background. Second, the TTB sets the following minimum required type sizes depending on the the size of the container:

  • Eight or fewer fluid ounces – Minimum character size of one millimeter
  • More than eight fluid ounces and up to three liters – Minimum character size of two millimeters
  • More than three liters – Minimum character size of three millimeters

Finally, the TTB sets a maximum number of characters per inch depending on the type size of your text.

  • One millimeter – No more than 40 words per inch
  • Two millimeters – No more than 25 words per inch
  • Three millimeters – No more than 12 words per inch

Three cans of beer that got their labels COLA approved.

The Net Contents Are Improperly Displayed

Another potential pain point for COLA applications involves just how much fluid your containers, well, contain. Beer, wine, and spirits all have different standards when it comes to net contents, so it’s important to hone in on the specific rules for your particular product and label them appropriately.

Net contents for beer labels

For beer labels, the TTB has a variety of net contents ranges. As such, the TTB requires you to list net content depending on which range your product falls under:

  • Use fluid ounces or fractions of a pint for containers with less than a pint
  • Use “1 pint, 1 quart, or 1 gallon” for those exact measurements
  • Use either fractions of a quart or pints and fluid ounces for containers with more than one pint, but less than one quart
  • Use either fractions of a gallon or a mix of quarts, pints, and fluid ounces for containers with more than one quart, but less than one gallon
  • Use gallons and fractions thereof for containers with more than one gallon

Net contents for wine labels

While beer regulations for net contents allow for a wide range of sizes, wine follows a set list of options. Wine bottles must abide by the TTB’s authorized standards of fill. This means that wine containers must hold one of the following amounts of fluid.

  • 50 milliliters
  • 100 milliliters
  • 187 milliliters
  • 375 milliliters
  • 500 milliliters
  • 750 milliliters
  • 1 liter
  • 1.5 liters
  • 3 liters

According to the TTB, containers with less than a liter of wine should state net contents in milliliters, while those with more than a liter should use liters and decimal portions rounded to the nearest hundredth of a liter (ex. 1.5 liters). In addition, the text for net contents should use the following sizing rules:

  • At least 1 mm for containers with 187 milliliters or less
  • At least 2 mm for containers with more than 187 milliliters

While the TTB has the set authorized amounts at the moment, that may change in time. The TTB released a notice in July to consider the elimination of all standards of fill except for a 50 milliliter minimum and a 3.785 maximum. The period for public comments on the notice closed Oct. 30, so the TTB should make a ruling at some point in the future after it weighs public feedback.

Net contents for spirits labels

Like wine, spirits containers have certain standards of fill. However, these standards differ slightly depending on your specific container.

  • Bottles and other non-can containers
    • 50 milliliters
    • 100 milliliters
    • 200 milliliters
    • 375 milliliters
    • 750 milliliters
    • 1 liter
    • 1.75 liters
  • Non-resealable metal containers in the general shape and design of a can
    • 50 milliliters
    • 100 milliliters
    • 200 milliliters
    • 355 milliliters

The TTB does make some exceptions to the standards of fill for specialty products like bitters, cordials, and other products. Regardless, any containers of 200 milliliters or more require the net contents to be at least one-quarter inch in height (containers with less than 200 milliliters are unspecified).

A row of Rockmill Brewery beers on a shelf, each of which received TTB label approval.

You Added New Text without Approval

It’s pretty common to change part of your label at some point. Between updating some of the language or adjusting your design, you may want or need to reprint your label. Some changes are completely fine according to the TTB, such as the following examples.

  • Delete non-mandatory label information, graphics, and other elements
  • Reposition approved label information
  • Change colors, shapes, and proportionate sizes of labels
  • Adjust type size, font, and spellings of words as long as it complies with regulations
  • Change the net contents statement for new container sizes
  • Change the mandatory statement of alcohol content as long as the change is consistent with the class and type designation

While those changes won’t lead to any issues, there are others that are off limits when done without the TTB’s knowledge. If you make a change that’s not on the allowed list and the TTB audits your products, they can pull the offending products due to non-compliance. As such, you’ll want to obtain a new COLA depending on your planned changes.

Make Your Beer, Wine, and Spirits Labels Shine with the Right Printing Company

Once you get your COLA approved for a brand-new label or some changes to an existing design, it’s time to find a good digital label printing company to get your products ready for sale. Blue Label has the state-of-the-art equipment and printing experts to help you determine the right materials and printing capabilities for you to get the most out of your label design.

Ready to dazzle your customers with quality beer, wine, and spirits labels? Contact us today to talk to us about your next label printing project.