The TTB Modernizes? Shelton Brothers Push The F’ing Envelope

TO OL + Shelton Brothers - Modernizing the TTB?
TO OL + Shelton Brothers – Modernizing the TTB?

First of all, big thanks to my favorite beverage law blog – BevLog – for bringing this to my attention. It appears that the often fearless Daniel Shelton, of famed beverage importer Shelton Brothers, has decided that the “queen mother of dirty words” (thanks Ralph) no longer meets the definition of “obscene or indecent.” Because if that “F – – -” word was, the TTB certainly would not approve of it.

Thanks to Danish brewer To Ol and Shelton Brothers, we are getting a sneak peak at the TTB’s new line of thinking. I am virtually certain that the TTB didn’t simply miss that word in its review – because the same word appears in 4 different submissions for the same brewery.

Well then, its the 21st Century. Go with it, eh?

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TTB Continues Impressive Streamlining of Its Procedures

Labeling submission requirements are seeing changes.

 

Back in September, I mentioned that the TTB had decided to try and cut the fat from its existing COLA procedures. My article discussed one of their efforts, a reduction of the personalized label submission requirements. But the TTB has been streamlining its procedures elsewhere.

 

Thanks to the good people at BevLog (a must follow alcoholic beverage law blog),  I was able to get my hands on a recent post by the TTB. The post describes their entire Certificate of Label Approval Streamlining Efforts, including both those already accomplished and those in the pipeline.

 

BevLog has so kindly PDF’d the webpage and provided it on their own site for your viewing. But here is a rundown of some of the important changes that might make your label submission duties a bit less burdensome:

 

  • New e-mail suggestion box
  • No longer reviewing labels for type size and other image file-related concerns
  • The aforementioned personalized label reduction
  • Implementation of Formulas Online (helps to simplify sample/formula submissions)
  • New website FAQ
  • More public disclosures of processing time

 

In the pipeline are these initiatives:

 

  • comprehensive revision of labeling regulations
  • changes to COLA Online
  • paper and online applications will be processed online
  • new forms

 

Stay tuned for more news on these long term changes. Many of those changes may require some additional training on your part.

 

 

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Beer Formulas: Collaboration Between Stone, Firestone and 21st Amendment Raises Eyebrows

Hey TTB - I'm beer.

Well this might not be a topic for dispute, but Stone Brewing‘s latest triangular collaboration has quite a label. The beer – El Camino (Un) Real Black Ale.

The new beer is a collaboration between Stone Brewing, 21st Amendment and Firestone Walker, three of California’s finest brewers. From a quick look at the ingredients, this new collaboration seems to be a spiced fruit basket of ale.

BevLog, one of our favorites beer law websites, ran a story about the new beer after seeing the label submission run across the TTB. As you probably know, the TTB is responsible for approving the labels of beers sold in the US. The mission is to ensure transparency and safety for the beer consumer.

Check out the label above – and be floored by the contents of this new ale. Ingredients such as chia seed, peppercorns, fennel seed and mission figs are seldom seen on your beer label. In fact, they probably remind you more of your easter lamb than your afternoon ale.

The BevLog did some brief research on the contents: (from their site)

This beer has a rather uncommon and unlikely combination of ingredients. The peppercorns are no great surprise, but the alcohol beverages with chia seeds seem to be few and far between. Wiki reports that chia is an Aztec word for oily, and these seeds contain large amounts of oil, omega-3 fatty acids, and antioxidants. (Un)Real El Camino Black Ale is also brewed with fennel seed and mission figs. It is a collaboration among several brewers and is bottled by Stone Brewing Co. in Escondido, California.

It does not appear that this beer was held up in submission to the TTB. But it is likely that it demanded a bit of research over there. Its nice to see brewers continuing to push the envelope with new and exciting formulas.

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Bevlog: A Useful and Entertaining Resource for Brewers

Bevlog is at the center of label submissions – needless to say, this Flying Dog label didn’t slide through

I stumbled across a wonderful website that is both informative and incredibly entertaining/intriguing that I thought we would share with the rest of you.

I have been searching for a viable and intriguing beer law blog for some time now. There just is nothing out there. In fact, if you were to google “beer law blog,” this column at BeerBlotter.com comes up on the first page. Wow.

One great site that does appear is BevLog, a blog put together by Lehrman Beverage Law, a firm headed by nationally known beverage lawyer, Robert C. Lehrman. Robert practices out in Virginia but certainly has an audience nationwide. Recently, he moderated a large panel NABCA (National Alcoholic Beverage Control Association) panel entitled “TTB and FDA: Working Side by Side to Regulate Alcohol Beverages.” He knows his stuff, and is constantly at the forefront of beverage law in the US.

Robert and attorney John Messinger edit BevLog. The blog’s main focus seems to be in the area of labeling and marketing regulations. As you probably know as a reader, or as you definitely know as a brewer, the US regulates labeling and marketing materials through the Food & Drug Administration (FDA) and the Alcohol & Tobacco Tax and Trade Bureau (TTB).

These two organizations work together (sometimes not nicely) to take brewer’s money and tell them whether or not their labeling and marketing materials are do not mislead consumers and are not obscene. Of course, they also regulate permitting, sales, transit, and content (FDA) of your beer.

But BevLog is an intriguing blog because the sole focus is to provide you with a glimpse of the most recent eye-catching labels that were approved by the TTB.

From the site:

TTB approves well over 100,000 labels per year. In these approvals you can see the bursting efflorescence of the American (and the world) economy….

bevlog reviews almost all of the 100,000+ beer, wine and spirits labels approved by TTB each year. We try to bring you the most noteworthy.

Check out the site. Recently they reviewed Lagunita’s new label for Wilco Tango Foxtrot, discussing the miltary implications implicit in the label.

If you have any great labels to throw their way, the site is set up to facilitate a dialogue.

I also act as the legal writer at BeerBlotter.com, providing that site with beer law articles. My column, Beer Law & Legis, will continue but will be mirror content produced here at BreweryLaw.com.

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