Blog / July 9, 2026
What You Can Change on an Approved Label Without a New COLA
Once the TTB approves your label, you do not have to refile for every tweak — but the list of what you can change on your own is exact.
By Zillah Bahar, Founder, COLAClear · July 9, 2026
A new COLA means another submission and another wait. The good news: the TTB lets you make a defined set of changes to an already-approved label without refiling. Knowing what is on that list — and what is not — can save you a filing, a delay, and sometimes a reprint. The catch: only changes on the TTB list qualify. Everything else needs a new COLA.
What the rule actually says
The TTB maintains a List of Allowable Changes to Approved Labels, printed on pages 3–4 of the COLA application (Form 5100.31) and on TTB.gov. If your revision is on that list — and stays compliant with 27 CFR Parts 4, 5, 7, and 16 — you can make it without a new COLA. If it is not on the list, you refile.
Common changes you CAN make without a new COLA
- Change the net contents to another TTB-authorized size.
- Change the alcohol content, within the allowed range for the class.
- Add, change, or delete the vintage date (within the vintage rules).
- Reposition or delete non-mandatory information; change type size, style, or color.
- Add or change a UPC barcode, lot/batch codes, or the bottling/production date.
- Change the name or address to one already approved, or to a different address within the same state.
- Add optional information such as an age or barrel statement, or average-analysis numbers (calories, carbohydrates).
Changes that still REQUIRE a new COLA
- The brand name.
- The class or type designation.
- The appellation of origin name. (You may change the percentage of grapes from an appellation without refiling — but not the appellation’s name.)
- The grape varietal designation.
- Adding brand-new graphics or statements not covered by the allowable list.
In short: anything that changes the mandatory identity of the product.
How to use it
Before you reprint, check your change against the current list on Form 5100.31. On the list — go ahead, and keep a record of what you changed. Not on the list — file a new COLA.
Where it goes wrong
- Assuming small changes are always allowed.
- Changing the appellation name, thinking it is like a percentage tweak.
- Adding a new medal or graphic and assuming it is covered.
Where COLAClear fits
When a change does push you into a new COLA, a pre-screen makes sure the revised label clears the first time — instead of trading one delay for another. You can run a label free during beta at colaclear.com.
References: TTB Form 5100.31 — List of Allowable Changes to Approved Labels (pages 3–4), and 27 CFR Parts 4, 5, 7, and 16. This article is general information, not legal advice — confirm current requirements against the CFR before labeling or filing.
Related reading: How long does a TTB COLA take in 2026? — why avoiding an unnecessary refiling matters. See also 7 reasons TTB issues a “Needs Correction” notice.