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Personalized Labels

 

TTB has recently liberalized the treatment of personalized labels, such as a wine label with “Happy Birthday Bob.” No longer will it be necessary to burden your company, or the government, with paperwork to cover “Happy Birthday Steve” or Judy, Tom, etc.

TTB announced this change on September 21, 2011 in TTB Guidance 2011-5. The document supersedes a policy from about a year and a half earlier; the 2010 policy required a new approval for just about every variation (such as each wedding, retirement, Bar Mitzvah, graduation, anniversary, etc.). In liberalizing the policy, TTB said:

Our 2010-1 guidance did not allow certificate holders to change the artwork or graphics on personalized labels without resubmission of the labels for approval. We have reconsidered this requirement and now permit certificate holders to make changes to the graphics or artwork on a previously approved personalized label without having to apply for a new certificate of label approval.

The above label, from Llano Estacado Winery, is an early approval under the new policy. The new policy seems due at least in part to pressure from Sen. Schumer. He mounted a vigorous campaign, on this topic, over the past summer. His August 9, 2011 press release, noting the progress, said:

In the case of … personalized labels the TTB agreed with Schumer’s request to streamline the process saying, “Effective immediately, TTB will not require resubmission of labels due to changes in graphics or artwork.”  In the past, TTB permitted wineries to simply apply once for approval of a custom label template to ensure it contained the required regulatory and safety warnings, after which the winery could customize and personalize the artwork … to suit the specific event.  TTB then changed course to require individual approval of labels when changes were made to graphics and label components apart of the regulatory and safety warnings.  By working with industry stakeholders to find ways to streamline approval of these custom labels TTB could, in turn, help ease the current backlog of COLA applications.

The press release also noted:

New York wineries have recently reported that it can take at least one month to receive approval of an electronically-filed COLA application and two to three months for a paper application. Often, when wineries finally do receive feedback, it is with a rejected label and the necessary corrections, and at that point labels must be resubmitted and the COLA process must begin again. The TTB told Schumer itself that they have noticed a significant increase in the typical amount of time it takes for them to respond to requests for label approvals.

So far, it does not seem that the current personalization policy would extend all the way to other masses of labels, such as Molson and Twisted Tea (large numbers of labels with other sorts of small variations).

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alcohol beverages generally


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Answer Honestly: Would You Prefer Funny Molson Labels?

molson

Molson must be pretty darned excited about the prospects for the above marketing campaign. They seem to have hundreds of label approvals for variations on this theme. A lot of the “Answer Honestly” labels are quite amusing. Molson has a long way to go before passing Twisted Tea in the shocking hugeness of the number of labels submitted and approved.

This massive exercise tends to beg the question, why don’t they just submit a few labels, with a long list of approved permutations alongside. Perhaps TTB wants every one submitted separately but it’s still not clear why that should be the case, as opposed to the relatively common allowance for personalization (Happy Birthday Joe, Trudy, Eleanor, etc.).

Here are a few more good ones, among the hundreds. If you see good ones out in the market, please add them to the list by way of comments.

Answer Honestly, Would You Prefer….

  • To be half your height -OR- Twice your weight?
  • To be famous and hated -OR- Normal and respected?
  • To have the ability to play every musical instrument -OR- Speak every language?
  • To be able to change the past -OR- See the future?
  • To be stuck in a meeting -OR- Stuck in traffic?
  • To be ten minutes late for everything -OR- An hour early for everything?
  • To lose a winning lottery ticket -OR- Your hair?
  • To watch all TV in black and white -OR- Listen to all music in AM?
  • To have a time machine -OR- A money-making machine?
  • To be a corrupt mayor -OR- An honest lawyer?
  • To hypnotize with your eyes -OR- Your touch?
  • To be stuck on a deserted island with a supermodel -OR- A boat builder?
  • To be rich -OR- Good looking?
  • To have your dream house in the Arctic -OR- Be homeless living on a beach?
  • To date someone who talks too much -OR- One who rarely speaks?
  • To have a constant toothache -OR- No teeth at all?

Sign me up for writing the next 500 questions (especially if it comes with free beer, a year on a tropical island, and a fat budget).

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malt beverage


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Mass Customization: Tons of Twisted Tea

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.

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flavored malt beverage, malt beverage


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