The COLA (TTB F 5100.31) for distilled spirits: what TTB checks and how to avoid corrections

Form

TTB F 5100.31, Application for and Certification/Exemption of Label/Bottle Approval (a “COLA”)

Who files

The bottler or importer of the distilled spirits

Where

COLAs Online

TTB fee

None

TTB median review

8 days (85% within 15 days), per TTB’s processing-times page

Rule

27 CFR 5.21 (COLA required to bottle spirits)

What happens after you file

TTB approves the application, or returns it as Needs Correction. TTB’s FAQ says you then have 30 calendar days to fix it; if you don’t, the status becomes Rejected, and you can file a new application later. Approval isn’t guaranteed, and nobody can promise it.

Points that most often need correcting

• Brand name entered wrong

  The brand on the label must be entered exactly in the application, with the class or type in its own field.

• Formula first

  Products that need a formula under 27 CFR 19.348 should have it approved before the label is filed.

• Name and address

  The bottler or distiller statement must match your permit.

• Health warning

  Exact wording and format: “GOVERNMENT WARNING” in capitals and bold (27 CFR 16.21, 16.22).

• Class and type

  The designation has to fit the standards of identity in 27 CFR part 5, subpart I.

Rule-based check points from the regulations cited; not TTB statistics.

Step by step

1. Finish the artwork. Final label images, at actual size, every panel that will be on the container.
2. Pre-check every mandatory statement. Brand, class/type, alcohol content, net contents, name and address, health warning and any statements your product needs.
3. File in COLAs Online. Submit TTB F 5100.31 with the label images. TTB charges no fee.
4. Answer corrections fast. If TTB returns it as Needs Correction, you have 30 calendar days to respond, or the application is rejected.

Related

• TTB F 5110.41, DSP registration and permit
• TTB F 5110.40 / .11 / .28 / .43, DSP monthly reports
• TTB F 5000.24, Excise Tax Return
• TTB F 5100.51, formula
• TTB F 5000.8, Power of Attorney
• Deadline calendar
• Glossary of terms

Sources

Checked Oct 28, 2026. Rules change; always confirm with the current regulation or TTB before you rely on a date.

1. 27 CFR 5.21 (COLA required to bottle spirits)
2. TTB distilled spirits labeling rules, 27 CFR part 5
3. 27 CFR part 16 (health warning)
4. TTB: COLAs Online and Formulas Online FAQs (C23, Needs Correction)
5. TTB: eApplication statuses in COLAs Online (PDF)
6. TTB: Label processing times

Questions