New Proof/Cask Strength Registration

MadelineCMadelineC Posts: 1
edited June 2015 in State Compliance
The market has seen a lot of change recently for "small batch" items and "cask strength" items. More demand for something that is not mass-produced and something that is unique and represents an age when life wasn't so mainstream and fast paced.

Because of this some of the products we have out in the market today vary in proof from batch to batch. 

The TTB allows a proof change as an acceptable change, and therefore, a new COLA does not need to be issued.

However, the states require a proof change a required registration as either a product revision or a new brand. The state of MO required a sample bottle of the finished product. The severely impacts the MO market when we are waiting for state approval. There are always orders held up in MO and other states that we have to wait for an approval. 

Is anyone else out there coming across a lot of time spent on registration for proof changes? 

Just wanted to get some feedback! 
Post edited by MadelineC on


  • We have similar issues with Missouri as well when it comes to spirits. When states require a physical, finished sample of the product it slows the time to market considerably in comparison to others. If they allowed a lab test or a sample bottle instead, it would be a little easier and make the process move a little quicker. (In Missouri you can actually submit a lab analysis in place of a finished bottle, but this isn't widely advertised.)

    Our home state, Michigan, is also a pain seeing as we are a control state with strict registration deadlines and any change in liquid or label (even if it is federally accepted) requires a new submission. 

    We also brew beer, and Texas is a prime example of spending too much time on "proof" changes. When we recently had a beer brand ABV change,  they required finished bottles be sent to the state for analysis or that we have a third party analysis done. The ABV has to fall within 0.25% over/under for the state to approve. 

    In some states even little tweaks to the imagery require a new COLA, regardless of whether or not the TTB requires it.

    It would make everyone's lives easier if the TTB and state alcohol regulators could get on similar pages. I do not think (most) states are even aware of the acceptable changes the TTB allows to COLAs.

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