Editor’s Note: Andrew Zender is the founder of ‘The Beer Label Guy,’ a compliance management consultancy that helps streamline regulatory approvals for breweries. As a former marketing manager for a mid-sized craft brewery, Zender helped to develop and launch new brands, redesign labels, change packaging formats and gain state approval as the company expanded its distribution.
In his column for Brewbound Voices, Zender highlights some of the common mistakes that can slow the beer label approval process and outlines some of the label changes that require breweries to submit a new COLA.
Those two words are sure to elicit an eye-roll or a facepalm from most craft brewers.
Few enjoy processing COLAs, state brand registrations, licenses, permits, regulatory approvals and applications. It’s time-consuming, but it’s also a necessary evil of running a brewery business.
I must be in the minority because I dig it. My top two bookmarks are COLAs Online and ShipCompliant.
How did it come to this?
A few years ago, I had an awesome job as a marketing manager at a regional brewery with about 20 brands and an 18-state distribution footprint. When I wasn’t running a social media campaign, cranking out sell sheets or churning through labels and packaging proofs, I was submitting COLAs and registering brands with a slew of state alcohol agencies. At the time, COLA processing times could take as long as 30 to 40 days. Now, the Alcohol Tobacco Tax and Trade Bureau (TTB) can process COLAs in three days.
As sales grew, we switched from 4-packs of 16 oz. cans to 6-packs of 12 oz. cans, and somewhere in the middle of that process, we re-branded the entire portfolio. All of this occurred while we expanded distribution into new states, eliminated a few brands and introduced some new ones.
Through all of the changes, I learned to conquer COLAs quickly and efficiently. I also learned to love the process. Each new brand, label or package was a fresh challenge, an opportunity to do it better.
When my job was eliminated as part of a reorganization earlier this year, I decided to launch a business focused on compliance management. Why? Because of two additional words that’ll make craft brewers’ blood boil: “corrections needed.”
Only 80 percent of the 100,000 COLA applications submitted to the TTB in the past five years have been approved — and more than half of the COLA applications submitted in the first quarter of 2017 were sent back for corrections.
Navigating the complex world of federal and state regulatory approvals can be a frustrating, perplexing and downright cumbersome process. What once passed on a label previously might now get nitpicked. What might seem clear to a brewery owner could be confusing to a label reviewer, and therefore deemed misleading.
Needless back-and-forth, correspondence, design revisions, label corrections — it all adds up to lost time and headaches. A delayed label approval process can lead to production disruptions, slower shipment times or delayed product launches.
According to the TTB, the six most common mistakes on COLA applications are:
- Class/Type is Missing
- General Misleading
- Formula Requirement
- Clarification Needed
- Brand Name Does Not Match
- Alcohol Content in Wrong Format
Label applications are also rejected for mistakes in stating net contents, the health warning and geographic origin — or for claims of alcohol strength, obscene or indecent material, and suggesting products have been endorsed by the U.S. military or government.
There are bright spots, however, like allowable revisions.
Have you recently added the Brewers Association’s independent craft brewer seal to your labels? Are you adding or revising an alcohol content statement? These adjustments are allowable revisions and don’t require a new COLA.
Here are some changes that require a new COLA:
- Adding new text that wasn’t on the previous label
- Changing the artwork or brand identity
- Going from one label (can) to multiple labels (brand front, back, neck)
- Changing class or type
The label review business isn’t cut and dry. National, regional, mid-size and small, under-resourced breweries all struggle with the process. Staying on top of compliance is extremely important and allows breweries to focus on what matters most — making great beer and connecting with their fans.