After obtaining a permit for production of distilled spirits, the producer must obtain federal approval for the labeling of the product. This is done by obtaining a certificate of label approval (COLA). Depending on the product being produced at the distilled spirit plant, this may require a pre-COLA product evaluation.
The pre-COLA evaluation can consist of laboratory analysis, pre-import letter, or formula approval.
The TTB provides a calculator to determine if a pre-COLA evaluation is necessary: https://www.ttb.gov/formulation/do-I-need-a-formula.shtml
The TTB also provides charts to determine if pre-COLA evaluation is necessary: https://www.ttb.gov/industry_circulars/archives/2007/pre-cola_eval_spirits.pdf
If laboratory analysis is deemed necessary, a 750 ml sample with complete list of ingredients and a description of how the product was manufactured must be shipped to National Laboratory Center, Beverage Alcohol Laboratory 6000, Ammendale Road, Beltsville, MD 20705. This analysis can take up to a month. Chemical analysis will be conducted and, if determined to be generally recognized as safe, the formula application will be approved.
If formula approval is required, a producer may submit the Formula Approval Form (TTB F 5100.51) electronically through the use of the formula online system or a paper copy of TTB F 5110.38. Pre-import letter may be required for some imported products. Using the formula online system is highly encouraged.
The requirements for laboratory analysis, formula approval, and pre-import letter can be found here: https://www.ttb.gov/formulation/pre_cola.shtml
Formula and Process for Domestic and Imported Alcoholic Beverages (TTB F 5100.51) can be found here:
https://www.ttb.gov/forms/f510051.pdf
Formula and COLAs online login can be found here: https://www.ttbonline.gov/ttbonline/
Once the pre-COLA requirements are fulfilled, the certificate of label approval can be obtained. This is done by submitting the labeling through COLA online or by paper submission via TTB F 5100.31. The label must be meet all legal requirements, which can be found in