The Business of Hard Cider - Allowable Label Revisions
- [Carla] On September 29th, 2014, an amendment was passed with the Alcohol, Tobacco Tax and Trade Bureau, to expand allowable revisions to your already approved hard cider labels.
This will allow you to make quick reasonable changes to your labels without applying for a new Certificate of Label Approval or COLA.
Let's take a look at the new allowances.
Under the new expansion, you're able to make very specifically outlined changes to your promotional graphics, a claim of a rating, award, or recognition, organic labels, your sulfite statement, batch numbers, or instructions on how your consumers should serve or consume your beverage.
Okay, now let's examine what you're allowed to change in each of these categories.
In the graphics category, you're able to delete or change sponsorship graphics or logos, including artwork, dates, event locations, or other information related to a specific sponsorship.
However, just be sure to check with your sponsors first to be sure any revisions are allowed by your partnering third party.
It's always good to keep a record of labels or graphic changes on file in case you need to refer to them in the future.
Here's a quick example of an event label for a corporate client.
This would be an allowable change under the rule.
This amendment also allows you to change, add, or delete a label or sticker that provides information about a rating or recognition you may have received.
Just be sure not to make any substantive claims about the product or your competitors.
It's always best to be fair to your competition.
Additionally, you have the option to delete all organic references from your label.
However, if you delete one claim, you must delete them all.
The deletion of individual references or certifications of organic claims is not permitted without a new COLA.
To change your sulfite statement, the rules provide choices.
You can choose from any of the options listed below, but make sure they are exact.
You're also able to change information regarding batch numbers.
This allows for the addition, deletion, or alteration of information about the numbers of bottles you've produced per batch.
Lastly, you're able to choose from a list of approved statements or instructions on how your consumers are to serve or consume your beverage.
Just remember, the seven topics covered here are an expanded, allowable list of changes to your label that do not require you to reapply for your certification of label approval.
Happy cider making.
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