Complying with TTB: Formula Approval and COLA

.
January 27, 2026
FDA labeling

Meeting TTB (Alcohol and Tobacco Tax and Trade Bureau) requirements can be complex, involving multiple steps to properly market alcoholic beverages in the U.S. Among these are the Formula Approval and COLA (Certificate of Label Approval), which are required once the TTB authorizes your product for U.S. distribution.

What is formula approval?

As a preliminary step to COLA, Formula Approval requires an in-depth review of certain wines, beers, and distilled spirits to ensure compliance with U.S. regulations. Not all beverages need this review—only those with specific characteristics. According to the TTB, the “formula” is defined as the recipe of an alcoholic beverage: a complete list of ingredients and the step-by-step production method. In some cases, samples may also be required for laboratory analysis.

Products requiring this additional formula review generally contain additives like colors or flavors. If you’re unsure whether your formula requires review, the TTB offers a link where you can complete a questionnaire to confirm: Which Alcohol Beverages Require Formula Approval | TTB: Alcohol and Tobacco Tax and Trade Bureau

To understand why some alcoholic beverages require a formula review, it’s important to consider U.S. regulations designed to ensure consumer safety, as certain ingredients may be prohibited. Furthermore, product characteristics determine applicable taxes and labeling requirements.

As mentioned, the Formula Approval process should be completed in advance, as lab analysis may be required, and adjustments may be necessary if the formula is not approved. Thus, domestic producers should complete this step before production, while importers should do so before importing the product to the U.S. Without approval, products may be detained at customs, incurring additional costs. An important consideration in this process is that flavors used must be pre-registered with the TTB, which requires the company registered in the U.S. as a producer or importer of the flavoring agent to complete the registration.

COLA: Label Certification

The COLA is the next step after Formula Approval, or if no formula review is needed. This certification, issued by the TTB, ensures that the alcoholic beverage’s label meets all U.S. federal labeling regulations, guaranteeing that the information on the label is accurate. It is required for wines, beers, and distilled spirits with more than 7% alcohol intended for the U.S. market. The review assesses elements such as health warnings, alcohol content, country of origin, and labeling format.

Regulations and compliance responsibility

The responsibility for submitting the Formula Approval or COLA to the TTB lies with the domestic producer of the alcoholic beverage or, for foreign producers, the person with a TTB Importer’s Basic Permit who imports the alcohol. If the producer is abroad and Formula Approval is required, they must support the process by providing the information TTB needs about the formula.

Each type of beverage—whether wine, beer, or distilled spirit—has specific regulatory requirements. For beverages with less than 7% alcohol, such as ciders, meads, or fermented drinks, the FDA may regulate the labeling instead of the TTB. This certificate must be requested for each product label, and the process is conducted entirely online. Any significant change to an approved label requires a new certification process. The primary objective of these requirements is to protect consumers and ensure products are distributed safely.

This process aims to guarantee consumer safety and provide essential information for responsible consumption. For producers and importers, meeting these requirements also provides the opportunity to expand within the U.S. alcoholic beverage market legally and securely.

We know that meeting all the requirements can be overwhelming and often confusing. It’s common to feel uncertain about meeting TTB standards and facing the risk of product removal from the market. Don’t worry; CORE consultants are here to help you determine if your product needs to go through the Formula Approval process or proceed directly to COLA. Contact us to ensure compliance and bring your alcoholic beverage to the U.S. market as soon as possible.

Complying with TTB: Formula Approval and COLA

.
January 27, 2026
FDA labeling

Meeting TTB (Alcohol and Tobacco Tax and Trade Bureau) requirements can be complex, involving multiple steps to properly market alcoholic beverages in the U.S. Among these are the Formula Approval and COLA (Certificate of Label Approval), which are required once the TTB authorizes your product for U.S. distribution.

What is formula approval?

As a preliminary step to COLA, Formula Approval requires an in-depth review of certain wines, beers, and distilled spirits to ensure compliance with U.S. regulations. Not all beverages need this review—only those with specific characteristics. According to the TTB, the “formula” is defined as the recipe of an alcoholic beverage: a complete list of ingredients and the step-by-step production method. In some cases, samples may also be required for laboratory analysis.

Products requiring this additional formula review generally contain additives like colors or flavors. If you’re unsure whether your formula requires review, the TTB offers a link where you can complete a questionnaire to confirm: Which Alcohol Beverages Require Formula Approval | TTB: Alcohol and Tobacco Tax and Trade Bureau

To understand why some alcoholic beverages require a formula review, it’s important to consider U.S. regulations designed to ensure consumer safety, as certain ingredients may be prohibited. Furthermore, product characteristics determine applicable taxes and labeling requirements.

As mentioned, the Formula Approval process should be completed in advance, as lab analysis may be required, and adjustments may be necessary if the formula is not approved. Thus, domestic producers should complete this step before production, while importers should do so before importing the product to the U.S. Without approval, products may be detained at customs, incurring additional costs. An important consideration in this process is that flavors used must be pre-registered with the TTB, which requires the company registered in the U.S. as a producer or importer of the flavoring agent to complete the registration.

COLA: Label Certification

The COLA is the next step after Formula Approval, or if no formula review is needed. This certification, issued by the TTB, ensures that the alcoholic beverage’s label meets all U.S. federal labeling regulations, guaranteeing that the information on the label is accurate. It is required for wines, beers, and distilled spirits with more than 7% alcohol intended for the U.S. market. The review assesses elements such as health warnings, alcohol content, country of origin, and labeling format.

Regulations and compliance responsibility

The responsibility for submitting the Formula Approval or COLA to the TTB lies with the domestic producer of the alcoholic beverage or, for foreign producers, the person with a TTB Importer’s Basic Permit who imports the alcohol. If the producer is abroad and Formula Approval is required, they must support the process by providing the information TTB needs about the formula.

Each type of beverage—whether wine, beer, or distilled spirit—has specific regulatory requirements. For beverages with less than 7% alcohol, such as ciders, meads, or fermented drinks, the FDA may regulate the labeling instead of the TTB. This certificate must be requested for each product label, and the process is conducted entirely online. Any significant change to an approved label requires a new certification process. The primary objective of these requirements is to protect consumers and ensure products are distributed safely.

This process aims to guarantee consumer safety and provide essential information for responsible consumption. For producers and importers, meeting these requirements also provides the opportunity to expand within the U.S. alcoholic beverage market legally and securely.

We know that meeting all the requirements can be overwhelming and often confusing. It’s common to feel uncertain about meeting TTB standards and facing the risk of product removal from the market. Don’t worry; CORE consultants are here to help you determine if your product needs to go through the Formula Approval process or proceed directly to COLA. Contact us to ensure compliance and bring your alcoholic beverage to the U.S. market as soon as possible.

Do you still have questions after reading the article?

Contact our specialists today and ensure the success of your import or export process—avoiding costly mistakes, delays, and compliance issues.
Learn more

We are your strategic partner

At CORE, we protect your investment, reduce risks, and guide you with global expertise to help you grow in national and international markets. Let’s talk about your project — we’re ready to support you.
Contact us today