TTB Newsletter for April 10, 2026

 

Electronic Payments Mandate

April 10, 2026 Top Tip from a Brewery Investigator: Make Sure Your Kegs are Correctly Labeled

As you prepare products for distribution this season, now is a great time to double-check that your kegs are correctly labeled. Kegs are considered consumer containers—just like bottles and cans—and when a Certificate of Label Approval (COLA) is required, they must meet all mandatory labeling requirements. Keg label format: Mandatory information may appear on keg collars, caps, stickers, or a combination of these formats. You may handwrite required information on your keg labels if needed, except for the health warning statement (Government Warning), which must always appear in its compliant, fully legible format. Firmly affixed labels: Generally, keg labels must be firmly affixed so that they cannot be removed without water or another solvent. For kegs of at least 5.16 gallons, labels are also considered firmly affixed when they break or become unusable upon removal. For kegs of at least 5.16 gallons that have the bottler or importer’s name permanently or semi-permanently displayed, labels do not need to be firmly affixed; however, there is no exception for firmly affixing the Government Warning. Common labeling errors to avoid: TTB investigators frequently find issues with keg labels, including: Missing mandatory information Multiple class/type designations appearing without clearly identifying which applies to the product Alcohol content left blank in a dedicated space for alcohol by volume Non‑compliant Government Warning statements—for example, incorrect capitalization or missing punctuation Taking a moment to confirm that your keg collars and other labeling components meet these requirements can help you ensure your kegs remain fully compliant. Malt Beverage Labeling

Top Tip from a Distillery Investigator: Gauge Every Time It’s Required We require distilled spirits to be gauged at numerous points in the production, storage, and removal processes to ensure accurate tax determination and regulatory compliance.   Gauging is the determination of the quantity and the proof of distilled spirits (and, where applicable, wine or alcoholic flavoring materials). Requirements for gauging are set forth in 27 CFR Part 19, Subpart K-- Gauging, including general gauging requirements, when gauges must be performed, and special rules for particular kinds of gauges.   When gauging is required:   Spirits, wine, and alcoholic flavoring materials must be gauged when required by a TTB officer, or when they are:    (a) Produced and entered for deposit; (b) Filled into packages from storage tanks; (c) Transferred or received in bond; (d) Transferred between operational accounts; (e) Mixed in the manufacture of a distilled spirits product; (f) Mingled under § 19.329 (when wines or spirits of less than 190° of proof are mingled in a tank); (g) Reduced in proof before bottling; (h) Voluntarily destroyed; (i) Removed or withdrawn from bond; (j) Tax determined; (k) Returned to bond; or (l) Denatured.   See 27 C.F.R. 19.283, When gauges are required.   Resources for accurate gauging:   The specific procedures for gauging, including the types of instruments that may be used, can be found in 27 CFR Part 30--Gauging Manual. TTB’s Proofing Videos provide instruction on how to proof your spirits correctly.   A helpful way to keep track of gauges is to keep a gauging log with the information required in 27 CFR 19.618, Gauge record. Having a running log makes reporting easier and helps to ensure that you won’t miss a required gauge.   Distilled Spirits Resources Top Tip from a Winery Investigator: The Bottler Gets the COLA There is often confusion around who must obtain a Certificate of Label Approval (COLA)—particularly when wine is bottled under various business models. The answer: the bottler is responsible for obtaining the COLA prior to bottling. This applies across the board, including these common scenarios:   Custom crush:   A “custom crush” arrangement involves an agreement or formal contract under which a customer pays a wine producer to produce wine to order, after which the customer markets the wine. In these arrangements, where the producer bottles the wine for the customer, the producer is responsible for obtaining the COLA. The customer, even if they own the grapes or design the label, does not apply for the COLA.   Alternating proprietors:   Alternating proprietors are independently qualified bonded winery operators who take turns using shared space and equipment. When bottling occurs under such an arrangement, each alternating proprietor who bottles wine is responsible for obtaining a COLA for the wine it bottles.   This is true even when proprietors share bottling lines. The responsibility follows the entity that actually bottles the wine—not the host winery.   Unlabeled bottles (“Shiners”):   Some wineries bottle wine without labels for storage or aging, or to be sent elsewhere for labeling. While regulations require the bottler to obtain a COLA prior to bottling, the labels do not need to be affixed until removal from bonded premises for consumption or sale. These bottles are often referred to as “shiners.”   The bottler is responsible for obtaining the COLA—regardless of where the labels will ultimately be applied. When unlabeled bottles are transferred in bond to another bonded wine premises for labeling:   The COLA must accompany the wine so the receiving premises can apply the approved label correctly. The transferee’s labeling premises acts as an agent of the bottler, not as the responsible party. The bottler remains accountable for the accuracy of label claims and for ensuring the label is covered by a valid COLA. If the wine is simply being transferred for aging and will be returned to the bottler for labeling, the COLA does not need to accompany the shipment—but the bottler still retains full responsibility.   See FAQ W8 for more information on responsibilities when transferring unlabeled bottles or bulk wine in bond. See Industry Circular 08-04 for more information on custom crush arrangements and alternating proprietors.   No matter the arrangement—custom crush, alternating proprietors, or handling shiners—remember that the obligation to obtain a COLA always rests with the bottler.   Wine Labeling Resources Visit Us at the American Craft Spirits Convention!

If you plan to attend the American Craft Spirits Association (ACSA) Convention in Sacramento, CA, come meet our team! We will be conducting a 2-hour Boot Camp on Thursday, April 16 from 2:30-4:30 pm. The session will give you an overview of the audit process and is designed to help you with distillery compliance, enabling you to feel confident in case of an audit. TTB specialists will also be available at the TTB booth in the expo hall throughout the conference to answer your questions and provide on-the-spot assistance with label, formula, and permit applications. As a bonus, we’ll have a chemist on hand to answer your proofing, testing, and lab questions. We look forward to seeing you there! TTB Distilled Spirits Resources What's Trending on TTB.gov: Taxes and Filing Tax Rates Due Dates for Tax Returns Electronic Payment Mandate Due Dates for Operational Reports Tax Payments by Electronic Funds Transfer

Upcoming TTB Outreach Activities April 17-18: American Craft Spirits Convention and Expo April 20-22: Craft Brewers Conference

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