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Labeling Updates from the TTB for United States Alcohol Beverage Products

Several updates from the TTB recently developed with respect to the alcohol beverage industry. These updates are noted below.

New Certificate of Origin Requirement for Exporting U.S. Alcohol Beverage Products to Korea: The recent trade agreement between the United States and Korea, along with its provisions, are particularly relevant for wine and alcohol beverage producers exporting products to Korea. The Agreement went into effect on March 15, 2012. (Read more about the trade agreement at U.S.–Korea Trade AgreementNew Opportunity for U.S. Exporters Under the U.S.–Korea Trade Agreement.) The Agreement is important to the alcohol beverage industry in the United States because it proposes to reduce and eventually eliminate tariffs on the exportation of alcohol beverages. The TTB, however, notes that a specific new addition is included in the Agreement: a certificate of origin for all U.S. alcohol beverages exported to Korea. For more information, see the TTB’s copy of the Korean–U.S. FTA Certificate of Origin necessary to claim a reduced tariff  and the Import/Export Requirements for Korea.

Alcohol and Tobacco Tax and Trade Bureau Announces Revisions to Certificate of Label Approval (“COLA”) Form: On March 30, 2012 the Department of Treasury published a notice in the Federal Registry for TTB Form 5100.31, Application for the COLA. This notice is succeeds a prior notice, 76 FR 81016, published by the TTB on December 27, 2011. The December notice sought comments from the public on changes the TTB advanced  with respect to the form, such as adding new types of changes that can be made to alcohol beverage labels without acquiring a new COLA for that beverage. “This [second] notice announces that the  Department of the Treasury has submitted the form to the Office of Management and Budget (OMB) for review and clearance in accordance with the Paperwork Reduction Act of 1995 and solicits comments on the form.” Comments for this Federal Register notice can be submitted to the TTB until April 30, 2012. To learn more about submitting a comment with respect to the March notice, see Revisions to TTB Label Approval Form

For more information on wine or alcohol law, TTB, labeling or COLAs, or advertising, please contact Lindsey Zahn.

DISCLAIMER: This blog post is for general information purposes only, is not intended to constitute legal advice, and no attorney-client relationship results. Please consult your own attorney for legal advice.

Lindsey A. Zahn


Lindsey is the founder and author of On Reserve: A Wine Law Blog. She is an alcohol beverage and food attorney and is admitted to the New York State Bar.

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