TTB clarifies label approval regulations for malt beverages

The Alcohol and Tobacco Tax and Trade Bureau (TTB) was asked to clarify the certificate of label approval requirements as they apply to brewers who are selling their domestically bottled malt beverages exclusively in the state in which the malt beverages were bottled.

On March 27, the TTB issued TTB Ruling 2013-1, which provides that the regulations implementing the Federal Alcohol Administration Act (FAA Act) do not require a brewer to obtain either a certificate of label approval or a certificate of exemption for a domestically bottled malt beverage that is sold exclusively in the state in which it was bottled.

The ruling also reminds brewers that even if a domestically bottled malt beverage is sold only in intrastate commerce, and therefore not subject to the labeling provisions in 27 CFR part 7, brewers must still comply with:

1. All applicable marking, branding and labeling requirements under 27 CFR part 25 for all beer removed from the premises, and
2. The health warning statement requirements imposed by the Alcoholic Beverage Labeling Act with regard to alcoholic beverages manufactured or bottled for sale or distribution in the United States.

If you’d like the longer version of this explanation, be sure to check out that 2013-1 ruling.