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COMPLIANCE MANAGEMENTFOR THE CRAFT BEER INDUSTRY
SERVICES
HAPPY CLIENTS
www.thebeerlabelguy.com
@thebeerlabelguy
785.477.5963
The Beer Label Guy helps streamline regulatory approval processes for breweries in the process of developing and launching new brands, redesigning labels, changing packaging formats and expanding their distribution territory.
““ ” ””The Beer Label Guy made the approval process far more efficient than we could have on our own, since we’re all busy with other facets of our brewery and don’t have as much time or energy to devote to compliance.
The Beer Label Guy streamlined our entire approval process as we refined our beer lineup and brought our labels into full TTB and state compliance. Highly recommended.
Brand Strategy: creative direction and copywriting in collaboration with graphic designers during label design phase. Bring your brand vision to life while meeting compliance standards.
Federal Approvals: start-to-finish management of COLA application process and communication with the TTB, including pre-COLA label reviews. Get it right the first time.
State Approvals: submitting brand registrations, distributor franchise agreements, appointment letters and territory designations via ShipCompliant, obtaining licenses for new markets, and managing correspondence with state agencies.
- Rock & Run Brewery & Pub
- Wichita Brewing Company- Kansas City Bier Company
“The Beer Label Guy brought all our brands into full TTB and state compliance as we grew distribution and switched packaging formats. He provided expert guidance on how to meet regulatory standards while staying true to the spirit of our brewery and our brands.
COLAs:AN OVERVIEW
100,000 80% 50%
MOST COMMON MISTAKES
WHEN YOU DO NEED A COLA
ALLOWABLE REVISIONS
BY THE NUMBERSwww.thebeerlabelguy.com
@thebeerlabelguy
785.477.5963
Information provided by the Alcohol and Tobacco Tax and Trade Bureau, 2017. Lists are not all-inclusive. All applicable laws and current regulations and requirements are detailed in full at www.ttb.gov.
COLAs submitted in past 5 years
Approval rate in past 5 years
Labels rejected in Q1 2017
1. Class/Type is Missing 2. GeneralMisleading/ClarificationNeeded 3. Formula Required 4. BrandNameDoesNotMatchonLabel/Application 5. Alcohol Content in Wrong Format 6. NetContentsinWrongFormat 7. Health Warning in Wrong Format 8. GeographicName/ProductOriginMisleading
1. When a malt beverage will be sold outside of the state in which it was produced/packaged 2. Adding of text or artwork that wasn’t on the previous label 3. Addition of new location listed on label 4. Going from one label to multiple labels (e.g., can to bottle front, back, neck) 5. Change in class or type
1. ChangeLabelSize(tofitdifferentcontainer) 2. ChangeNetContentsValue 3. Add/Deleted/ChangeanAlcoholContentStatement
� � � � � � � � � � � � � � � � � �� � � � � � � � � � � � � � � � � �� � � � � � � � � � � � � � � � � � � � � � �
Kansas City Bier Co. has found great success focusing exclusively on
brewing German-style biers, which they serve primarily out of their
bier hall and outdoor biergarten, with their three �agship beers in
bottles and dra� throughout the Kansas City area. �e Beer Label
Guy worked with brewery leadership as they re�ned their portfolio
into year-round, seasonal and specialty/limited releases and began
the process of deepening their distribution territory in Kansas and
Missouri.
�is project included the following regulatory compliance services
and expertise:
Pre-COLA label reviews, creative direction and copywriting
(keg collars)
Managing TTB COLAs and state approvals for 28 brands
(keg collars)
Fine-tuning and standardizing distributor franchise
agreements, appointment letters and territory designations
for Kansas and Missouri
“”
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
� � � � � � � � � � � � � � � � � � � � � � � � � � � � �� � � � � � � � � � � � � � � � � � � � ! "
Located in the Northland area of Kansas City, Rock & Run primarily
sells beer from their taproom and via limited distribution in
Missouri, attracting a loyal following with their small-batch brews
and tasty taproom fare. "e Beer Label Guy worked with brewery
leadership as they re#ned their core lineup of beers for dra$
distribution, developed a limited-release beer in a bomber bottle,
and expanded their distribution footprint into Kansas.
"is project included the following regulatory compliance services
and expertise:
Pre-COLA label reviews, creative direction and copywriting
(can label/keg collars)
Managing TTB COLAs and state approvals for six brands
(can label/keg collars)
Creating and standardizing distributor franchise agreement
and appointment letter
Obtaining out-of-state supplier permit from Kansas Alcoholic
Beverage Control
“”
# $ % & ' ( ) & * + , % ' % - & ' . / , + ' % , & ' - / , * $% 0 & , $ 1 / 2 ' 3 . 4 ' 3 % ' 5 , 1 $ ) 2 . 5 ' 6 . $ %2 ' 3 ) ' % 0 5 * 4 / . , $ 7 8 9 # 5 6 5 / . / ' . ) ) & * + . 3 5. $ % . $ * 0 / : * ; : 5 / . / ' 3 , - ' $ 5 ' ( , / 2 1 & ' . / ' . 5 ' <- * 0 3 % 2 . + ' * $ * 0 & * ( $ 6 5 , $ - ' ( ' = & ' . 3 34 0 5 > ( , / 2 * / 2 ' & ; . - ' / 5 * ; * 0 & 4 & ' ( ' & > . $ %% * $ = / 2 . + ' . 5 ? 0 - 2 / , ? ' * & ' $ ' & 1 >/ * % ' + * / ' / * - * ? ) 3 , . $ - ' < @ 2 ' ' $ / , & ') & * - ' 5 5 ( . 5 + ' & > 5 ? * * / 2 <A B C D C E C F G H CI C J K L M C N C M O P N D C M O I C J K L C C M B C C QR S F Q T R H D L M C N C M U T V H W
� � � � � � � � � � � � � � � � �� � � � � � � � � � � � � � �� � � � � � � � � � � � � � � � � � � ! " #
Wichita Brewing Company serves hand-cra�ed pizzas and beer at
its two brewpubs and also operates a production/canning facility for
its beers distributed throughout Kansas. �e Beer Label Guy worked
with brewery leadership as they shi�ed production from tallboy
cans to 12 �. oz. cans, revised labels to be fully compliant with TTB
standards, and begin the process of expanding their distribution
footprint into Missouri.
�is project included the following regulatory compliance services
and expertise:
Pre-COLA label reviews, creative direction and copywriting
(can labels and keg collars)
Managing TTB COLAs and state brand label approvals for
12 brands (can labels and keg collars)
Creating and standardizing distributor franchise agreement
and appointment letter
Obtaining out-of-state supplier permit from Missouri
Alcohol & Tobacco Control
“”
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
PLANNING FOR UNCERTAINTY Strategies to Protect Your Brewery in a Rapidly Changing Market
NEGOTIATING DISTRIBUTION SUCCESSFULLY The Inside Guide to Maximizing Your Business and Brands
MONEY MANIA Funkwerks Cofounder Brad Lincoln on Their Deal with Brooklyn
CASE STUDIESNESHAMINY CREEK Finds Growth in Reviving and Rebranding a Defunct Brewpub
CROOKED STAVE Is an Independent Distribution Arm the Secret to In-State Success?
JACK’S ABBY Stays True to Brand by Launching a Second One
PLUS MUCH MORE!
GREAT NOTION BREWINGFrom Average Brewpub to Industry Leader in Twelve Months or Less
CRA
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& B
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WIN
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DIRECTORY OF BREWING EQUIPMENT AND SERVICE PROVIDERS //// DEVELOP YOUR DIGITAL STRATEGY
BREWINGINDUSTRYGUIDE FALL
2017
CRAFT
PRACTICAL ADVICE
COLA SUBMISSIONS MADE EASIERFor cra� brewers, navigating the complex world of federal and state regulatory approvals can be a frustrating pro-cess. In the �rst quarter of 2017, more than half of all labels submitted to the Alcohol and Tobacco Tax and Trade Bu-reau (TTB) were rejected for corrections. This means spending more time on design revisions, resubmitting labels, and, possibly, delays in getting products to market. Here are �ve basic tips to help avoid having your labels rejected by the TTB. BY ANDREW ZENDER, THE BEER LABEL GUY
ALCOHOL CONTENTThere are a handful of ways to state the alcohol content of your product, and the everyday expression “ABV” isn’t one of them. But that’s the term we all use in conversation, right? Even though most of us simply say “ABV” when talking about how much boozy punch we can expect to get out of our favorite imperial stout or how “sessionable” an IPA is, the TTB doesn’t accept the everyday abbreviation as an adequate way of stating alcohol content. Instead, try “Alc./Vol.” with the percentage in front (e.g., “6.5% Alc./Vol.”).
CLASS AND TYPE/COMPOSITION STATEMENTIn this exciting period where craft brewers are pushing the envelope with their beers and ingredients, things can get muddy with label approvals. But one thing is clear: Properly identifying a beer’s class and type is key to getting a label approved.For example, although “IPA” is an everyday term that’s about as common as hops are in an IPA, it won’t work by itself on a label, per TTB standards. You can still use “IPA” as part of your brand/beer name; just be sure to include “India Pale Ale” elsewhere on the label. Even “Ale” will suRce. But make sure it meets type size and legibility requirements (more on that in a moment).In addition, once you get into using
ingredients other than water, malt, hops, and yeast, adjunct ingredients must be properly identiSed in a composition statement, depending on when and how
they’re introduced into the beer. Planning to have a coTee porter or peach beer in your lineup? You can call it that on your label, so long as the composition state-ment explains it—for example, Co"ee Porter or Porter with Co"ee Added; Peach Ale or Ale Brewed with Peaches.
TYPE SIZE AND LEGIBILITYGet creative with your branding and graphic design, but don’t get so carried away that you fail to meet type size and legibility re-quirements for all mandatory information. What exactly does that mean? All mandatory information on a label, excluding alcohol content and health warning statement, must
▪ be at least 2mm high for containers larger than a half pint (8 fl oz); ▪ be readily legible; ▪ appear on a contrasting background; ▪ appear separate and apart from, or be substantially more conspicuous than, descriptive or explanatory information.
To put it simply: if you think an element of your label might be unclear to the TTB, it probably is. Design your labels so each piece or section of mandatory information is easy to read and easily identiSable.
NET CONTENTSWhether it’s in bottles, cans, or kegs, beer comes in many diTerent package sizes—bombers, 12s, tallboys, the “stovepipe” can, half-barrels, and sixth-barrels, to
name a few. When identifying the net contents of your product, American units of measure are most common, but metric measure also is accepted. Depending on the size of the container, use ^uid ounces, pints, gallons, and fractions thereof.
NOTES FOR THE SPECIALISTThe TTB wants to minimize or eliminate potential consumer confusion when it comes to the overall branding and design of alcohol products. While the name you’ve chosen for your beer/brand and the design you’ve used to represent it may be clear to you, it may not be to a TTB label review specialist, and therefore, to a con-sumer. In fact, just assume it isn’t. Take the time to write a concise, compelling statement that explains the beer’s name, label design and color, and the overall marketing strategy behind the brand and include it in the notes to the specialist during the COLA application process.
IN CLOSINGOne Snal piece of advice: take a look at some of your favorite beers on the shelf, particularly those from outside your home market. They all had to meet federal requirements to get there. Find inspiration from your fellow breweries.
Andrew Zender, The Beer Label Guy, o�ers
consulting and process management services
to the beer industry for TTB COLA registration,
state brand and label registrations, and state
license applications. For more information,
visit thebeerlabelguy.com.
18 // BREWING INDUSTRY GUIDE 2017
CRAFT
BREWINGINDUSTRYGUIDE FALL
2017
What two words are sure to elicit an eye-roll or a facepalm from many craft brewers?
Compliance Management. Things like COLAs, state brand registrations, licenses, permits, regulatory approvals and applications. Few enjoy managing these processes. They’re time-consuming, necessary evils and nowhere near as fun as making beer.
But the reality is they’re absolutely critical in the concept-to-market process. When compliance is mismanaged, it creates headaches, costs money and creates delays. It can turn into a big, nasty distraction from why brewers got into the business, which is to, you know, make beer. Right?
I’m proud of my ability to dissect a beer label, wordsmith and churn through paperwork and applications the way a mill grinds malt. I wasn’t always this way, though. How did this happen?
I formerly served as marketing manager for a regional brewery with about 20 brands and an 18-state distribution footprint. When I wasn’t overseeing everything that falls under the marketing umbrella, I also acted as the brewery’s de facto compliance manager, submitting COLAs, writing and keeping record of distributor appointment letters and franchise agreements, registering brands with a slew of state alcohol agencies and getting on a first-name basis with their staff, and applying for supplier licenses, sales representative licenses. This is why people got into the beer business, yes?
In the midst of Q2 2016, we switched from 4-packs of tallboys to 6-packs of 12 oz. cans, and then, as if we needed another challenge, we rebranded the entire portfolio in the middle of that process — all while expanding distribution into new states, killing a few brands and replacing them with new ones. I became proficient in conquering compliance and found ways to streamline the process so I could get back to tasks like coming up with beer names and making Instagram videos.
But I learned to love compliance, and earlier this year, I decided to become The Beer Label Guy. Knowing how knotty the process can be, I wanted to help other breweries save time, resources and headaches as they develop and launch new brands, update their packaging formats and expand their distribution.
I enjoy compliance management because it allows me to tap into two conflicting halves of my professional self: the side that enjoys creating, tinkering and collaborating; and the side that enjoys project management, structure, order, neatness and adhering to deadlines.
Navigating the complex world of federal and state regulatory approvals can be a frustrating, perplexing and downright cumbersome process. I’ve seen it. The label review business isn’t so cut and dry.
In the end, one thing is clear: staying on top of compliance is extremely important and allows breweries to focus on what matters most — making great beer and connecting with their fans.
Let me sweat the approvals so you can focus on the fun stuff.
Cheers!Andrew ZenderThe Beer Label Guy
HOW I LEARNEDTO STOP WORRYINGAND LOVE COMPLIANCE
AN ESSAY BY THE BEER LABEL GUYwww.thebeerlabelguy.com
@thebeerlabelguy
785.477.5963