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  • James Niekamp

How to Submit TTB "Use-Up" Requests for Non-Compliant Labels

Cans without labels

Gaining a Certificate of Label Approval or “COLA”, often feels like the final step in federal label compliance, but TTB compliance is an ongoing and evolving process that includes keeping all labels compliant. But what happens if the labels are no longer accurate? This article will explain how to submit "use-up" requests for non-compliant labels.

TTB understands that there are circumstances where a label may not be strictly compliant with labeling requirements set by the FAA Act. In these cases, TTB allows for a “use-up” request for the non-compliant labels on a case-by-case, temporary approval basis. TTB reviews these requests on a case-by-case basis and will only grant approval in cases where consumers will not likely be misled by the non-compliant label. Additionally, TTB wants to see a reason as to why these non-compliant labels need to be used. This could involve explaining the economic impact of having to destroy or not use the current non-compliant labels. 

To gain “use-up” approval, a written request must be submitted to TTB’s Advertising, Labeling, and Formulation Division including the following information:

  1. Brand name, serial number, or TTB ID for the non-compliant labels. The COLA(s) must be attached to the written request. 

  2. The reason(s) for requesting permission to “use up” the non-compliant labels. This is where you can explain the economic impact of destroying the current labels. 

  3. The reason you have non-compliant labels. This could include, but is not limited to administrative errors, regulations changes, changes in formulas, etc.

  4. Any steps to be taken to ensure this does not happen in the future. 

  5. The quantity of non-compliant labels on hand and the area of distribution for the labels. 

  6. The length of time you need to “use up” the remaining labels. 

  7. Any suggestions of alternatives to using non-compliant labels. For example, this could be adding a strip label or a stamp.  

While TTB understands the circumstances that result in non-compliant labels, they want to ensure consumers are not misled by the non-compliant labels. In order for TTB to ensure the labels are not misleading, they need all important information as well as time to process the application. If you have any questions regarding labeling compliance, contact the Alcohol Labeling and Formulation Division or visit TTBGov - Labeling Resources for more information on labeling compliance.


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