Keg Collar Labeling Requirements for Craft Breweries
It seems like labeling regulations change about as quickly as tap handles at your brewery. Regulations for kegs are no exception.
As you know, kegs are an integral part of any brewery’s process. Whether you are shipping coast to coast, or just filling for your tap room, it is important to have your kegs labeled correctly according to TTB standards.
You can find the most up to date beer laws and regulations, here at Alcohol and Tobacco Tax and Trade Bureau’s (TTB) website: https://www.ttb.gov/beer/beer-regs.shtml
TTB is the governing federal agency over all beer labeling. However, you should still check your local and state regulatory agencies, as laws may vary by location.
Since we print labels and shrink sleeves for many breweries across the U.S., we wanted to make it easier for breweries to get to the specific information they need regarding labeling regulations. This article is designed to help get you up to speed on keg collar labeling requirements.
(Disclaimer: we are not legal experts and this article should not be viewed as legal advice, but merely a tool to get to specific parts of the TTB’s regulatory documents).
Do TTB’s keg labeling requirements apply to my brewery?
The TTB describes a container for breweries as:
“Any can, bottle, barrel, keg, or other closed receptacle, irrespective of size or of the material from which made, for use for the sale of malt beverages at retail.”
According to Title 27: Chapter 1: Subchapter A: Part 25-Beer: Section 25.2, the territorial extent for these regulations are as follows, “This part applies to the several States of the United States, the District of Columbia and the Commonwealth of Puerto Rico.”
Meaning that these labeling regulations apply to the majority of breweries within the United States who are brewing beer for the purpose of sale and distribution.
Where the regulations and requirements for breweries get interesting regarding keg labeling, are under Subpart J – Marks, Brands and Labels: General Requirements.
Under Part (b) – (1) and (2) TTB describes the two sizes of containers applicable to brewers. Either containers more than one-half pint, or less than one-half pint. Kegs would fall under the larger container size category.
Because of kegs being defined in part (b-(1)), it also means they are applicable to part (d) of section 7.28 – General Requirements which states that, “Labels firmly affixed. All labels shall be affixed to containers of malt beverages in such manner that they cannot be removed without thorough application of water or other solvents.”
Part (c) of section 25.141 requires that all keg collars must be approved.
“Label approval required. Labels or tap covers used by brewers shall be covered by certificates of label approval, Form 5100.31, when required by part 7 of this chapter.”
In light of these requirements, LabelValue is now offering both custom and stock keg collar label solutions. These labels are waterproof and come standard with our permanent adhesive that will withstand the cold, damp environment of your keg filling and distribution needs. We offer high quality digital print capabilities for custom, as well as a stock, generic keg collar that can be written upon with the applicable information needed.
As of June 7, 2018 these are the updated regulations for proper keg labeling:
You must include:
Brewery/Brand Name & Brewery Address:
(a) The brewer’s name or trade name and the place of production (city and, if necessary for identification, State) shall be permanently marked on each barrel or keg. If the place of production is clearly shown on the bung or on the tap cover, or on a label securely affixed to each barrel or keg, the place of production need not be permanently marked on each barrel or keg. No statement as to payment of internal revenue taxes may be shown.
(b) Breweries of same ownership. (1) If two or more breweries are owned or operated by the same person, firm, or corporation (as defined in §25.181), the place of production:
(i) May be shown as the only location on the bung, or on the tap cover, or on a separate label attached to the keg:
(ii) May be included in a listing of the locations of breweries qualified under this part if the place of production is not given less emphasis than any of the other locations; or
(iii) Need not be shown if the brewer’s principal place of business is shown in lieu of any other location. The brewer’s principal place of business will be the location of a brewery operated by the brewer and qualified under this part.
(2) If the location of two or more breweries is shown on the keg, bung, tap cover, or on a separate label attached to the keg (paragraph (b)(1)(ii)), or if the brewer’s principal place of business is shown in lieu of the actual place of production (paragraph (b)(1)(iii)), the brewer shall indicate the actual place of production by printing, coding or other markings on the keg, bung, tap cover, or on a separate label attached to the keg. The coding system employed will permit an appropriate TTB officer to determine the place of production (including street address if two or more breweries are located in the same city) of the beer. The brewer must notify the appropriate TTB officer prior to employing a coding system.
Beer Class & Type:
(a) The class of the malt beverage shall be stated and, if desired, the type thereof may be stated. Statements of class and type shall conform to the designation of the product as known to the trade. If the product is not known to the trade under a particular designation, a distinctive or fanciful name, together with an adequate and truthful statement of the composition of the product, shall be stated, and such statement shall be deemed to be a statement of class and type for the purposes of this part.
Section 7.22 Mandatory Label Information, also states that the beer label must include:
(4) Net contents (except when blown, branded, or burned, in the container) in accordance with §7.27:
Section §7.27 states:
(a) Net contents shall be stated as follows:
(1) If less than 1 pint, in fluid ounces, or fractions of a pint.
(2) If 1 pint, 1 quart, or 1 gallon, the net contents shall be so stated.
(3) If more than 1 pint, but less than 1 quart, the net contents shall be stated in fractions of a quart, or in pints and fluid ounces.
(4) If more than 1 quart, but less than 1 gallon, the net contents shall be stated in fractions of a gallon, or in quarts, pints, and fluid ounces.
(5) If more than 1 gallon, the net contents shall be stated in gallons and fractions thereof.
(b) All fractions shall be expressed in their lowest denominations.
(c) The net contents need not be stated on any label if the net contents are displayed by having the same blown, branded, or burned in the container in letters or figures in such manner as to be plainly legible under ordinary circumstances and such statement is not obscured in any manner in whole or in part.
Alcoholic Content (ABV):
Additionally, dependent on the state you brew in, alcoholic content by percentage may be stated on a label unless prohibited by law:
(a) General. Alcoholic content and the percentage and quantity of the original gravity or extract may be stated on a label unless prohibited by State law. When alcoholic content is stated, and the manner of statement is not required under State law, it shall be stated as prescribed in paragraph (b) of this section.
(b) Form of statement. (1) Statement of alcoholic content shall be expressed in percent alcohol by volume, and not by percent by weight, proof, or by maximums or minimums.
(2) For malt beverages containing 0.5 percent or more alcohol by volume, statements of alcoholic content shall be expressed to the nearest one-tenth of a percent, subject to the tolerance permitted by paragraph (c) (1) and (2) of this section. For malt beverages containing less than 0.5 percent alcohol by volume, alcoholic content may be expressed in one-hundredths of a percent, subject to the tolerance permitted in paragraph (c)(3) of this section.
(3) Alcoholic content shall be expressed in the following fashion: “alcohol—percent by volume,” “alcohol by volume—percent,” “—percent alcohol by volume,” or “—percent alcohol/volume.” The abbreviations “alc” and “vol” may be used in lieu of the words “alcohol” and “volume,” and the symbol “%” may be used in lieu of the word “percent.”
(c) Tolerances. (1) For malt beverages containing 0.5 percent or more alcohol by volume, a tolerance of 0.3 percent will be permitted, either above or below the stated percentage of alcohol. Any malt beverage which is labeled as containing 0.5 percent or more alcohol by volume may not contain less than 0.5 percent alcohol by volume, regardless of any tolerance.
(2) For malt beverages which are labeled as “low alcohol” or “reduced alcohol” under paragraph (d) of this section, the actual alcoholic content may not equal or exceed 2.5 percent alcohol by volume, regardless of any tolerance permitted by paragraph (c)(1) of this section.
(3) For malt beverages containing less than 0.5 percent alcohol by volume, the actual alcoholic content may not exceed the labeled alcoholic content. A malt beverage may not be labeled with an alcoholic content of 0.0 percent alcohol by volume unless it is also labeled as “alcohol free” and contains no alcohol.
(d) Low alcohol and reduced alcohol. The terms “low alcohol” or “reduced alcohol” may be used only on malt beverages containing less than 2.5 percent alcohol by volume.
(e) Non-alcoholic. The term “non-alcoholic” may be used on malt beverages, provided the statement “contains less than 0.5 percent (or .5%) alcohol by volume” appears in direct conjunction with it, in readily legible printing and on a completely contrasting background.
(f) Alcohol free. The term “alcohol free” may be used only on malt beverages containing no alcohol.
General Label Guidelines:
Subpart C of the TTB guidelines, also mandates that the Health Warning Statement be present on all alcoholic beverages for sale or distribution within the United States:
(a) Domestic products. On and after November 18, 1989, no person shall bottle for sale or distribution in the United States any alcoholic beverage unless the container of such beverage bears the health warning statement required by §16.21. It is the responsibility of the bottler to provide, upon request, sufficient evidence to establish that the alcoholic beverage was bottled prior to November 18, 1989.
(b) Imported products. On and after November 18, 1989, no person shall import for sale or distribution in the United States any alcoholic beverage unless the container of such beverage bears the health warning statement required by §16.21. This requirement does not apply to alcoholic beverages that were bottled in the foreign country prior to November 18, 1989. It is the responsibility of the importer to provide, upon request, sufficient evidence to establish that the alcoholic beverage was bottled prior to such date.
§16.21 Mandatory Label Information
There shall be stated on the brand label or separate front label, or on a back or side label, separate and apart from all other information, the following statement:
GOVERNMENT WARNING: (1) According to the Surgeon General, women should not drink alcoholic beverages during pregnancy because of the risk of birth defects.
(2) Consumption of alcoholic beverages impairs your ability to drive a car or operate machinery, and may cause health problems.
For minimum size requirements, the TTB gives guidelines you should follow:
(a) Legibility. (1) All labels shall be so designed that the statement required by §16.21 is readily legible under ordinary conditions, and such statement shall be on a contrasting background.
(2) The first two words of the statement required by §16.21, i.e., “GOVERNMENT WARNING,” shall appear in capital letters and in bold type. The remainder of the warning statement may not appear in bold type.
(3) The letters and/or words of the statement required by §16.21 shall not be compressed in such a manner that the warning statement is not readily legible.
(4) The warning statement required by §16.21 shall appear in a maximum number of characters (i.e., letters, numbers, marks) per inch, as follows:
Minimum required type size for warning statement
Maximum number of characters per inch:
1 millimeter 40
2 millimeters 25
3 millimeters 12
(b) Size of type. (1) Containers of 237 milliliters (8 fl. oz.) or less. The mandatory statement required by §16.21 shall be in script, type, or printing not smaller than 1 millimeter.
(2) Containers of more than 237 milliliters (8 fl. oz.) up to 3 liters (101 fl. oz.). The mandatory statement required by §16.21 shall be in script, type, or printing not smaller than 2 millimeters.
(3) Containers of more than 3 liters (101 fl. oz.). The mandatory statement required by §16.21 shall be in script, type, or printing not smaller than 3 millimeters.
And again, the TTB states that all labels bearing this required statement should be applied in such a way that they cannot be easily removed:
(c) Labels firmly affixed. Labels bearing the statement required by §16.21 which are not an integral part of the container shall be affixed to containers of alcoholic beverages in such manner that they cannot be removed without thorough application of water or other solvents.
Additional Requirements From Distributors
Many distributors also wish to see information such as the date the beer was brewed. Keg collars also offer an opportunity for QA when bottling kegs or shipping. As well as suggestions of when to consume by, and other warnings your brewery may see fit to include.
Remember, keep up-to-date on the ever-changing label requirements
It is important to remember that these regulations are updated regularly, and the intent of this article is to give you, the brewer, a brief overview of what you can expect for labeling your kegs.
You should always consult the TTB guidelines for all alcohol labeling. Always go through the proper TTB COLA approval process before placing any orders for keg collar labels.