Posts Tagged ‘policy’
Class & Type Must Stand Alone
In the above example, it is not sufficient to have VODKA on the front label. Or, the right size. In addition, it needs to be “separate and apart” from other matter. TTB has gotten more strict about this over the years. The above rejection is from a few days ago. The vodka label is from many years ago, to show the movement in the policy, or the enforcement of the policy.
TTB is quite concerned about word placement and proximity. For example, “absinthe” must appear next to other words, as here. Vodka may not, as above. It is important to understand the various proximity rules, because they can lead to unpleasant surprises, and because they extend from spirits to beer and wine. It is probably not okay to bury the word “chardonnay” amidst a sentence singing its praises. It is probably not okay, in most instances, to affix several words before and after BEER.
The rule can be difficult because it’s not always clear how much separation is required (A few spaces? A few line breaks?). It’s not always clear why some terms get treated differently (such as “Silver Rum” or “Cream Liqueur”). It is easy enough to add an extra class/type statement to the front label, to avoid any difficulties (such as adding VODKA to the above label, on its own line) — but only if you know the rule early enough.
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Beer with Style
On this label, the Nova Scotia heritage is pretty big and prominent. Even though the beer is made in downtown St. Louis.
The look is probably saved by the equally big reference to “style,” and the not so big reference to Missouri. Shock Top provides another example of the power of “style.” The label proclaims Belgian in medium-sized letters on the front label, and this is saved by the nearby reference to “style” — also on the front label of this other beer made in the middle of the U.S.
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Sparkling Vodka
We covered several sparkling spirits products about three years ago, here, and so it may be about time for a redux. There is quite a bit of action on this front, in recent months, perhaps due to the high profile of Nuvo Sparkling Liqueur.
Here is a Sparkling Vodka under the brand name Le Grand Saint. Technically, it is a distilled spirits specialty more than a “vodka” or a specific class/type. The statement of composition (“vodka infused with carbonation”) appears in gold letters near the top of the front label.
Another good example is Prévu. It is unique in the sense that it is sparkling, and liqueur, and organic. It is made with vodka and Cognac, and imported by Simont Enterprises of Los Angeles, California. Prévu also happens to have a great looking website and bottle. If the product is even half as good as what is shown there, I should step away from the computer and go get several bottles.
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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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personalized, policy, procedure
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Founding Fathers Beer
Part of the challenge and complexity is that label rules and trends change often. As recently as a few years ago, TTB would balk about pre-eminently famous people, such as these, on alcohol beverage labels. Founding Fathers Beer is bottled by CBC Latrobe in Latrobe, Pennsylvania. I tend to doubt that TTB would allow a President Obama label, even today (except maybe as a caricature), but George Bush, Bill Clinton and the prior Presidents may well be fair game now or soon.
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famous, history, policy, political, speaks for itself
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