TTB has been working on a new COLA form, with new and more flexible rules about what may change without seeking a new label approval. TTB announced this in the January 13, 2012 Newsletter and the Federal Register two weeks prior.
The new rules, if/when implemented, could allow a huge variety of big and small changes — without the need to submit, wait, haggle.
Here is the draft form. For example, the new rules (at page 3) would allow you to:
- Move mandatory around. This is at category 2. This would allow you to move VODKA from the bottom of the front label to the top of the front label, for example. It would not allow you to move VODKA from the front to the back. (The draft form does not seem to make it clear, about whether it’s also okay to reposition non-mandatory. It would be very strange if okay to move the important stuff but not the less important stuff.)
- Change colors. This is at category 3.
- Add/delete/change a QR code. This is at category 22.
- Add/delete/change social media icons. This is at category 25.
- Add/delete/change information about awards. This is at category 26. It remains a bad idea to announce “Award for most antioxidants in a Cabernet.” ...