Blog / October 29, 2026
Holiday Labels: What You Can Change Without a New COLA
Dressing up an approved label for the holidays? TTB lets you add seasonal artwork and greetings without refiling, as long as you stay inside the lines.
By Zillah Bahar, Founder, COLAClear · October 29, 2026
It’s the season for snowflakes, wreaths, and “Happy Holidays” on the bottle. If your label is already approved, here’s the good news: you don’t need a new COLA to give it a holiday look. The catch is knowing exactly where that permission ends.
What the rule actually says
TTB’s List of Allowable Changes to Approved Labels, printed on the COLA form (TTB F 5100.31), includes this item:
28. Add, delete, or change holiday- and/or seasonal-themed graphics, artwork and/or salutations.
You don’t file anything or notify TTB. You make the change and keep it compliant. TTB attaches one condition:
Holiday/seasonal-themed information or graphics must not conflict with or qualify the mandatory information and must comply with all applicable regulations, including the rules governing prohibited practices.
What that covers
- Seasonal artwork: snowflakes, ornaments, a winter scene.
- Greetings: “Happy Holidays,” “Season’s Greetings,” “Cheers to the New Year.”
- A holiday color scheme. Changing colors, shape, and proportionate size is its own allowable change (item 3.a).
A few other items on the same list are handy for a holiday edition:
- A limited-run count, like “500 bottles produced” (item 33).
- A food pairing in TTB’s approved wording: “Best paired with [name of food]” or “Best served with [name of food]” (item 37).
- An approved serving line, such as “Best Served Chilled” or “Pour Over Ice” (item 34).
- The signature of your winemaker, brewer, or distiller (item 27).
Where it goes wrong
- The artwork crowds the mandatory information. Every mandatory statement still has to be readily legible, on a contrasting background, and in its required place. A snowflake over your alcohol content is a problem, however festive.
- A new name sneaks in. “Snowfall Red” isn’t a graphic or a greeting. It’s a name, and adding or changing a product name isn’t on the list. Changing the brand name takes a new COLA.
- The greeting turns into a claim. Item 28 covers salutations. A line that describes the product, rather than greeting the customer, is something else, so don’t assume it’s covered.
- It’s really a different product. A spiced, peppermint, or other flavored holiday version is a new product, not a label change. It needs its own label approval, and flavored products often need TTB formula approval first.
How to use it
Check your holiday version against the current list on Form 5100.31. If every change is on the list and your mandatory information is untouched and easy to read, you’re set. Keep a record of what you changed with your approved COLA. If anything falls outside the list, file a new COLA, and give yourself time: here’s how long a COLA takes in 2026.
Where COLAClear fits
When a holiday edition does need a new COLA, run it through COLAClear before you file, so the seasonal version clears the first time. It’s free during beta at colaclear.com.
FAQ
Do I need a new COLA to add holiday artwork to an approved label?
No. TTB’s list of allowable changes lets you add, delete, or change holiday- or seasonal-themed graphics, artwork, and greetings without a new COLA, as long as they don’t conflict with or qualify the mandatory information.
Do I have to tell TTB?
No. Allowable changes are made without resubmitting to TTB. Keep a record of what you changed.
Can I give the holiday version a new name?
Not under the allowable changes list. A new or changed name isn’t covered, and changing the brand name requires a new COLA.
References: TTB Form 5100.31 (04/2023), List of Allowable Changes to Approved Labels, items 3.a, 27, 28, 33, 34, and 37; TTB, List of Allowable Changes to Approved Labels; 27 CFR Parts 4, 5, 7, and 16. This article is general information, not legal advice.
Related reading: What You Can Change on an Approved Label Without a New COLA, the full list of allowable changes. See also How long does a TTB COLA take in 2026?