Personalized labels are special products offered by some importers, bottlers, and wholesalers directly to a consumer who wants a bottle, for example, to commemorate a special event such as an anniversary or wedding. They are distinct from private labels, which are created for purchasers other than the ultimate consumer of the wine (i.e. a house label wine in a restaurant).

Every wine label must be approved by the TTB and this approval is represented by a COLA obtained by the producer. However, personalized labels by their nature will be different for each customer, and as such the TTB has allowed producers of personalized labels to change the salutation, event dates, and names on the label without submitting each label to the COLA process. The previous guidelines did not allow changes to the artwork or graphics on personalized labels, however, without resubmission for approval. The TTB has now decided to permit such changes to the graphics or artwork on a previously approved personalized label without requiring a new application for a COLA, to better accommodate consumers in the market for a commemorative personalized labeling.

In order to obtain approval from the TTB to make changes for personalized labels, the applicant must indicate their intention on their initial COLA application. The applicant should submit a template that will be modified that, at a minimum, contains all of the mandatory information (as required by 27 CFR parts 4, 5, 7 and 16). Additionally, “the application must contain in item 19 of the paper application, or in the special wording section found in Part II/Step 2 in COLAs Online, a description of the specific personalized information that may change.” Further, “personalized statements, graphics, pictorial or emblematic representations that are not allowed on labels that undergo TTB review”  cannot be added to the template in creating the personalized label.

For more information, visit the labeling section of the TTB’s website.


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