TTB gets a lot of labels. For this brand alone, it appears the brewer submitted over 1,500 labels since 2003. Why? There are many reasons why brewers submit multiple variations for a given brand (state deposit rules, container sizes, alcohol content, etc.). But here, it is probably mass customization. Due to advances in printing, small run labels are becoming increasingly common. It’s not always necessary to submit every permutation, but here are three: above, Syracuse, wide stance.
We have a future product line for which we would like to utilize mass customization. (1) I see in your example COLAs that it says “previous versions are obsolete”, what if one would like several versions of the same label on the market at the same time with the only change being the photo ~ would one have to submit a COLA for each one? (2) You mentioned “it’s not always necessary to submit every permutation”. In what instances would one not have to submit?
Thanks for the comment Jeff. 1) “Previous versions obsolete” refers to the TTB paper form, not the approval. TTB is saying, don’t be using forms from the 1980s. 2) If you write nice and clearly, such as “Happy Birthday (name goes here with no reference to the product)” TTB may be willing to allow it. This would avoid separate approvals for Happy Birthday Joe, Steve, Shirley, etc. You would need to write it nice and clearly, to tamp down the possibility of getting into a sensitive area (such as “good for what ails you”).