Prepping Your Beer Label for TTB? Read This First

Disclaimers

First of all:
TTB submission can sometimes be in the eyes of the reviewer. Abide by their comments.

Secondly:
These might not be fully comprehensive of what you may see (per point one above), but should cover about 90%. We don’t take legal responsibility for any issues you see and by reading/implementing you take full responsibility.

Thirdly:
Your product must be submitted to COLA before you submit to the TTB.

Fourthly:
Font size and contrast for legibility are key things to keep in mind throughout.

Classes of Beer

Class is integral to TTB approval, and is usually the most common issue to get flagged.

This designation must occur somewhere on the label in a prominent fashion and reflect the following.

The Main Designations

These Apply to Products 0.5% ALC / VOL and higher

• Beer
• Ale
• Porter
• Stout
• Lager
• Lager Beer
• Malt Beverage

How it Works

If you call a beer “India Pale Ale” as your style designation you’re likely covered. If you shorten your style designation to “IPA,” then you’ll need to state “Ale” somewhere else on the label.

If your beer style doesn’t fit the above, it will need declared somewhere.

• Ex: Gose would be Ale, Dopplebock would be Lager or Lager Beer.

If you don’t know whether a style is an ale or lager, Google or Chatgpt have quick answers. Hopefully, however, if you work in beer it’s second nature.

What’s a Malt Beverage?

We’ll point to a famous example — White Claw.

Yes, it is a Malt Beverage as it’s made with seltzer water and a gluten-free malt base for alcohol.

Generally, Malt Beverage is anything in this realm made with malt-derived alcohol.

If the Beer is Less Than 0.5% ALC / VOL

Then it must be called:

1. Near Beer
2. Malt Beverage
3. or Cereal Beer

What About “Non-Alcoholic?”

A few thing to consider here:

• It must be less than 0.5% ALC / VOL
• It must say “Contains Less Than 0.5% Alcohol by Volume”
• You must call it Malt Beverage, too 
• You cannot call it beer if you use Non-Alcoholic.
  • If you want to, call it Near Beer and skip all of these steps and considerations

Here’s a visual example from the TTB showing does and don’ts here: 

If you’re dabbling in Non-Alcoholic products, view this presentation by the TTB here.

Geographical Style Designations (French-style Etc).

Be especially cautious if you’re adding a Country designator to the style.

• Example: German-style Lager, Belgian-style Ale, French-style Saison, etc.

If you add a country name to the style, it must either say:

• [country]-style [beer type] or [country]-type [beer type]. Examples: Belgian-style ale, Belgian-type ale
• or if you leave that off — example German Lager — you must state “Made in the USA” as to not create confusion as to where the product is created. You can tuck that somewhere as long as it’s legible

Here’s what the Law says verbatim:

‘Malt beverages labeled with geographical names must be produced in the particular region indicated by the name, unless TTB has found that the name has lost its geographical significance.

Geographically significant malt beverage styles produced outside the country or region indicated by the name must be properly qualified with the word “type,” “style,” “American,” “Product of USA,” or some other statement indicating the true place of production. For example, an ale produced in the United States may not be labeled as a “Belgian Ale” without the proper qualification, such as “Belgian Style Ale.” See 27 CFR 7.146.’

Alcohol Content

No, not our newsletter.

This refers to the Alcohol by Volume. This table from the TTB sums it up.

There are some rules to when you can avoid showing ALC / VOL on a label, but given State requirements we typically just recommend to have it.

From a consumer perspective, it’s also extremely helpful to assist with self moderation.

Brand Name

The label must supply a prominent “Brand Name” for the product. AKA: your beer name.

If there isn’t one, the brewery name is used as the Brand Name.

Type Size is Key for This

• Minimum 2 mm for containers larger than 1/2 pint;
• Minimum 1 mm for containers of 1/2 pint or less.

Contrast Requirements

The label requires enough color contrast to make the Brand Name legible. The TTB doesn’t supply much more information than this, so use discretion so you don’t get flagged.

Visual Obfuscation

Lastly, your Brand Name cannot be obfuscated by visual design elements.

If it is, then the easy solution is to repeat the Brand Name somewhere else in the label, like the sidebar.

For example:

The Brand Name showcased below “Mourning Paper” is obfuscated by the grave.

We repeated it legibly in the sidebar.

Net Contents

The label must clearly showcase the content volume.

The most common would be:

• 12 Fl. Oz or 12 Fluid Ounces
• 16 ounces must be stated as 1 Pint

There are a variety of acceptable ways to accomplish this. Here’s a graphic from the TTB directly to assist you:

Type Size is Key

• Minimum 2 mm for containers larger than 1/2 pint
• Minimum 1 mm for containers of 1/2 pint or less

Contrast, Too

Same rules as your Brand Name.

ALL CAPS Tends to Pass

Although it’s not explicitly mentioned in the TTB guidelines, we’ve found following the format with ALL CAPS doesn’t tend to get flagged and is acceptable.

• Ex: 12 FL. OZ

Government Warning

This is required for all labels.

• Government Warning must always be in ALL CAPS and bolded.

Like so:

GOVERNMENT WARNING: (1) According to the Surgeon General, women should not drink alcoholic beverages during pregnancy because of the risk of birth defects. (2) Consumption of alcoholic beverages impairs your ability to drive a car or operate machinery, and may cause health problems.

Brewed & Packaged By

The formula is as follows:

[Brewed & Canned (or Bottled) by [Brewery Legal Name]
[City and State]

Example:

• Brewed and Canned by Pittsburgh Brewing Company
  Creighton, PA

If you want to list your principal business address (rather than the production location), it’s an option, as long as it doesn’t seek to mislead consumers.

Example, if you’re official address is Millvale (a city touching Pittsburgh City Limits), you could say Pittsburgh, PA. Just know this might get rejected.

Additive Disclosures

Here’s a full list. 

From experience, however, if you’re adding anything in addition to hops, malt, and yeast you’ll need it called out.

Common examples include things like:

• Maple Syrup
• Peanut Butter
• Lactose
• Spruce Tips
• Coffee
• Vanilla Bean
• Fruit

There are two safe conventions here to get you in better alignment with approval:

• [Style name] [made or brewed] (optional) with [additives list]
• Or a separate note of Contains [additives list]

Examples:

• India Pale Ale with Lactose and Coffee Beans
• India Pale Ale made with Lactose
• Contains: Lactose, Coffee Beans, and Peanut Butter

Aging in Barrels

If you have a product aged in barrels, you should declare that too. Be sure to do that before the additives list.

For example:

• Imperial Stout aged in bourbon barrels with maple syrup added

Less Common, But Worth Considering

If you have either of the following, they need called out:

1. Sulfites
2. Aspartame

Do so like this somewhere on the label.

• CONTAINS SULFITES

It also must be ALL CAPS.

Other Things We’ve Seen

Here are some situations we’ve run into:

A phone on the label being charged can’t state % (charge) because it might be confused as the ALC / VOL

The art may not depict bodily harm (showed someone raising a beer out of water, but they thought it looked like someone drowning)

Now, this artwork actually ending up getting approved the second time. Again, sometimes reviews are in the eyes of the reviewer.

Questions?

We’re here to help.