COLA stands for Certificate of Label Approval. It's a federal approval required for most alcoholic beverages sold in the United States. If you're manufacturing, importing, or selling alcohol across state lines, understanding the COLA system is essential.
What is a COLA?
A COLA is issued by the TTB (Alcohol and Tobacco Tax and Trade Bureau), the federal agency that regulates the alcohol industry. It certifies that a product's label meets federal labeling requirements before that product can be sold.
Since the TTB began tracking approvals electronically, they've issued over 2.5 million COLAs. Approximately 3,000 new approvals are processed each week. The public database includes records going back to 1999, though earlier records have inconsistent data quality.
Who needs a COLA?
A COLA is required for products sold in interstate commerce. The requirement applies to:
- Distilled spirits (whiskey, vodka, rum, tequila, gin, etc.)
- Wine above 7% ABV (table wine, sparkling wine, dessert wine)
- Malt beverages shipped across state lines (beer, ale, hard seltzer)
- Other fermented products (hard cider, sake, mead)
The key factor is interstate commerce. Products sold only within the state where they're produced may qualify for exemptions.
Who submits the application?
- Domestic products: The manufacturer or bottler
- Imported products: The U.S. importer of record
For imports, the application is the responsibility of the U.S. importer, not the foreign producer.
Exemptions
Some products don't require a COLA:
- Malt beverages sold only in-state: Breweries that sell exclusively within their home state don't need a COLA. Labels must still comply with federal requirements, but the approval document isn't required.
- Certificate of Exemption: Wine and spirits sold only in the state where they're bottled can obtain an exemption instead of a full COLA. The label must state "For sale in [state] only."
Most commercial producers require COLAs. The exemptions apply primarily to small operations with limited distribution.
What the TTB reviews
When evaluating an application, TTB reviewers verify that labels comply with federal regulations. They examine:
- Mandatory statements: brand name, class/type, alcohol content, net contents, bottler/importer information
- Health warning statement: the federally mandated warning text must appear verbatim
- Prohibited claims: unsubstantiated health claims, misleading statements, or obscene content
- Product classification: whether the product meets the standards of identity for its claimed type
- Country of origin for imported products
The TTB reviews labels, not products. They don't evaluate taste, quality, or whether the product matches its description. Quality assurance is the producer's responsibility.
The application process
Step 1: Obtain required permits
Before applying for a COLA, you need a TTB basic permit. Manufacturers need a DSP (Distilled Spirits Plant), brewery, or winery permit. Importers need an importer's basic permit. Permit applications can take several months to process.
Step 2: Submit through COLAs Online
The TTB's online portal, COLAs Online, handles all submissions. Applicants complete form 5100.31, upload label images, and provide product details. There is no application fee.
Step 3: Review period
The TTB reviews submissions against labeling regulations. Processing time is typically 5 to 20 business days for straightforward applications. More complex submissions take longer.
Step 4: Decision
Applications receive one of three responses:
- Approved: The label may be used.
- Needs Correction: The label has issues that must be addressed, such as missing required statements or prohibited claims. Corrected applications are resubmitted and re-enter the review queue.
- Rejected: The application has significant issues that can't be resolved through correction.
Applications requiring correction are common. Each resubmission restarts the review timeline.
Processing times
Turnaround depends on TTB workload and application complexity:
- 5-15 business days for standard applications
- Several weeks for complex products or during high-volume periods
- Additional time for applications requiring corrections
The TTB publishes current processing times on their website. Build buffer time into product launch schedules.
After approval
COLAs don't expire. Once approved, a COLA remains valid indefinitely.
However, significant label changes require a new application. "Allowable revisions" that don't require reapplication include:
- Changing the vintage date on wine
- Adding or changing a UPC barcode
- Minor repositioning of label elements
- Correcting minor typographical errors
Substantive changes — new claims, different alcohol content, brand name changes — require a new COLA application.
Why COLAs matter
The COLA system exists to protect consumers. Pre-market label review ensures that:
- Consumers receive accurate product information
- Health warnings appear as required
- Marketing claims are not misleading
- Products are correctly classified for tax purposes
For industry professionals, the COLA system provides another benefit: market intelligence. Every approved COLA is public record. The registry shows what competitors are launching, what importers are bringing in, and how product categories are evolving — often before products reach retail shelves.
Accessing COLA data
The TTB maintains a Public COLA Registry where anyone can search approved labels. Records go back to 1999, and most include label images.
The TTB's search interface has limitations: restricted filtering options, slow exports, and no API access. For applications requiring scale — product catalog development, launch tracking, trend analysis — these limitations become significant.
COLA Cloud addresses these gaps. We sync with the registry daily, normalize the data, and add information not available in TTB records: extracted barcodes, OCR text from label images, and improved categorization. Access is available through a REST API or direct Snowflake connection.
Summary
- COLA = Certificate of Label Approval, issued by the TTB
- Required for distilled spirits, wine (7%+), and malt beverages sold across state lines
- Free to apply through COLAs Online
- Processing typically takes 5-20 business days
- Over 2.5 million COLAs have been issued, with approximately 3,000 new approvals weekly
- COLAs don't expire, but label changes may require new applications