This is a post about beer labels and appeasing the TTB.
We had the pleasure of designing some kickass can art for HopFly Brewing’s kickass summer beer series.
The designs were approved by the state of North Carolina (aww yeah!) but the process of seeking federal approval — which would give all 50 states the HopFly they deserve — made things a little more complicated.
Approval comes down to the discernments made by a government agency called the TTB, short for the Alcohol and Tobacco Tax and Trade Bureau.
While the designs have yet to make it through the TTB process, we’re here to share what we’ve learned.
Beer Packaging Approval, In a Nutshell
From their offices in Department of the Treasury, the TTB dictates what you can and can’t put on your beer labels.
The good news is, brewers are 100% allowed to sell their beer in the state it’s made — without federal approval — if that state approves the design. Look at these beauties on their home beach!
HopFly’s Summer 2018 beer series included Summer Crush, a New England IPA; The Jalapeño, a saison flavored (and heated) with jalapeño pepper; and more.
We had a lot of fun with this project. Our final designs depict quirky scenes of outdoor landscapes where man, beer and nature collide.
We loved ‘em. HopFly loved ‘em. They were submitted for TTB approval.
In multiple rounds of revisions and several months of time, the TTB put the language, government warnings, fluid volume numbers and artwork under their microscope.
Issue #1: The Artwork
First, they came for Summer Crush.
This label features a smart phone being electrified by jellyfish. The screen reads “110% battery.”
The TTB requested the percentage be removed, positing that “110%” could be confused with an impossibly high ABV.
We opted to replace the percentage with your universal, everyday charging bolt.
In the First Priority design, a hand emerges from water holding a HopFly can. The TTB asked: is that dude drowning?
Once, Twice, Then Nada
The TTB actually approved this artwork on first pass — not once, but two times.
It wasn’t until the third pass, when we had moved on to language revisions, that the illustration was presented as a concern.
However, it wasn’t clearly cited as rejected — the issue was just mentioned. So it was unclear whether or not we had a definitive problem.
Since HopFly wasn’t ready to cross state lines anyway, we decided not to pursue a fix for the hand. The artwork had already been approved in-state.
When they are ready to expand, we’ll have to try again. The TTB might give us a yes without issue, or we might need to investigate solutions. It still isn’t fully clear if they were going to reject the design or not.
Issue #2: The Language
Simpler to revise, the TTB called out several things with the verbiage on several labels.
A name issue
They require that “IPA” be written in full on the label as “India Pale Ale.” Fair enough.
A descriptor issue
A beer isn’t allowed to “ooze stone fruit and passion fruit.” However, it can have “aromas of” those things.
A beer-crushing issue
See: First Priority. The TTB deems “crushable” beer strictly off-limits.
However, once TTB approval went on hold, HopFly decided to keep it — just toned down a little. As you can see.
“Watering down juicy descriptions” is not our middle name, but we made these revisions easily enough.
Expect to revise, even if you’ve read all the instructions. Think of everything.
Emailing back-and-forth with the TTB is frustrating, at times. But the process doesn’t always take months — for example, our designs for Iron City Beer got approved by the TTB quickly and with no trouble.
Custom illustration is always likely to present gray areas that the TTB will take more time to decide on. Be ready for some surprises.
More HopFly? Yes, Please.
Want to see the rest of this juicy can art, in all its glory? We made you a case study. Check it out.