Label Approval FAQ

The information that follows is based on the TABC Code and Rules, and is meant as an aid to the label approval process. For more detailed information see TABC Rules Chapter 45. Information about the US Department of Treasury, Alcohol and Tobacco Tax and Trade Bureau (TTB) rules for federal Certificates of Label Approval (COLA) may be found on the TTB website.

General Questions

1. Why do I need a TABC label approval?
   
   

   By law, no person may ship or cause to be shipped into the State of Texas any alcoholic beverage unless the product has received label approval from this office.

Filling out the Label Approval Application

1. Where can I find the most current label approval applications?
   
   

   The current versions of the label approval applications are found on our Label Approval Forms page. Please use Form C-270DS for distilled spirit labels, C-270W for wine labels, and C-270MB for malt beverage labels.

2. Can label approval applications be submitted online?
   
   

   Not at this time.

3. Can I apply for label approval before I have received my TABC license or permit?
   
   

   No. Applications will not be accepted unless the licensee/permittee has a valid permit issued by this office.

4. What Trade Name should be listed on the label approval application?
   
   

   The Trade Name is the name under which the TABC license/permit was issued.

5. Is TABC label approval required for every size marketed in Texas?
   
   

   Malt Beverages: Yes, every size and every container type (bottle, can, or keg) must have a TABC label approval.

   Wine and Spirits: No, the TABC Rules mirror the TTB Rules for issuing COLAs. There must be at least one TABC label approval to cover sizes smaller than 237 ml, one TABC label approval to cover sizes from 237 ml to 3 L, and one TABC label approval to cover sizes greater than 3 L.

6. Is a separate application and fee required for each size or size range?
   
   

   Malt Beverages: Multiple sizes may be listed on one application, but the fee is $25 per size and container type (For example, 12 oz bottle and 12 oz can labels would have different labels and therefore both need approval).

   Wine & Spirits: Multiple sizes of exactly the same product may be listed on one application and the processing fee will be $25 for all sizes listed on the Federal COLA.

7. When sending multiple applications, can I provide one check to cover the total cost?
   
   

   Yes, one check or money order may be provided to cover the total cost for the label approval applications submitted.

8. Are product samples required for TABC label approval?
   
   

   Malt Beverage: Yes – all new product label approvals will require product samples for analysis. In lieu of samples, an analysis stating the alcohol content both by volume and by weight may be provided from an independent laboratory. Analyses from the brewery will not be accepted. For label revisions or size additions, a product sample or independent laboratory analysis will be required if the product test result on file at TABC is more than 5 years old. If you are unsure of the date of the last test result, please email your question to us (the tested alcohol content will be listed on the certificate of label approval if a sample was tested or an independent laboratory analysis was provided).

   Spirits: No.

   Wine: A product sample will be required if the alcohol content is less than 7% alc/vol and there is no TTB COLA available.

9. Where should product samples be sent?
   
   

   TABC, 5806 Mesa Drive, Austin, TX 78731. It is illegal to send alcoholic beverages through the US Postal Service. Most large carriers (FEDEX, UPS, and etc.) have the appropriate permits to transport alcohol in Texas, but you must confirm this prior to shipment.

Label Approval Processing and Certificates

1. How long does the label approval process take?
   
   

   Please allow 15 business days from the time the application is received at TABC.

2. Is there a procedure for expediting the label approval process?
   
   

   No, label approval applications are processed in the order received.

3. How do I know if my labels are approved?
   
   

   Label approval certificates will be sent through the US postal service and you may check the Approved Label / Product Inquiry.

4. Do TABC label approvals expire?
   
   

   As a rule, no, TABC label approvals do not expire. However, if the TTB COLA provided with the label approval application has an expiration date, the TABC label approval will also expire on that date. When changes are made to the label, which require a new TTB COLA, a new TABC label approval is also required.

Revisions and Brand Transfers

1. How do I know if a label revision will require a new TABC label approval?
   
   

   If your label revision requires you to obtain a new TTB COLA, then a new TABC label approval will also be required. You may also email your question to us. Malt Beverage brewers are encouraged to email electronic copies of labels for a preliminary opinion.

2. If the only change to a wine label is vintage, is a new TABC label approval required?
   
   

   Probably not. You will only be required to obtain a new TABC label approval if the TTB requires you to get a new COLA or the alcohol by volume changes the class of wine. (Lower wine tax class is 14.0% alc/vol and under, higher wine tax class is over 14% alc/vol).

3. My Company has acquired the rights to some brands that already have TABC label approval under the previous owner's TABC permit/license. Can I transfer those label approvals to my permit/license number?
   
   

   No, all products must be registered to the producer, owner, or exclusive agent of the commodity. However, you may send a letter to the TABC Label Approval Section stating that you have acquired the rights to these brands. Please list the brands that you have acquired and provide a copy of the use-up letter from the previous brand owner. The Label Approval section will confirm the labels have been registered in Texas. A letter will be issued stating the labels may continue to be used until new COLA's are obtained from TTB. As new COLAs are obtained from TTB, label applications must be submitted for state label approval.

4. My TABC permit/license expired, and I now have a new TABC permit/license number. Do I need to re-register the products under the new TABC permit/license number?
   
   

   No, as long as there have been no changes to the labels requiring new TTB COLAs, the TABC label approvals issued under the expired permit/license number are still considered current.

Other

1. Can product samples be provided or an order placed, before TABC label approval is received?
   
   

   No, product that does not have TABC label approval may not be shipped into the State of Texas prior to approval.

2. How is hard cider classified in Texas?
   
   

   Hard Cider is considered a specialty wine in Texas.

Have a question not covered here? Please email your question to us.