Guides
Brewery and taproom products packages: TTB label rules
Federal label rules for brewery and taproom products packages: TTB approval on Form 5100.31, the 27 CFR part 7 statements, and 27 CFR part 16 health warning.
What to take away
Brewery and taproom products packages are decided in a fixed order: license privilege, building and equipment, bar time at the Friday rush, then guest demand. This piece covers two ends of that order — what a label must state and how the fill behind the bar is run.
- Four gates decide which takeaway formats you may offerlicense privilege, building and equipment, bar time at the Friday rush, and guest demand. Run them in that order.
- Packaging labels are federal. Filled containers are state. TTB approves the label on a sealed can, while your alcohol board sets what a crowler or growler carries and how it closes.
- Typical field shelf life runs 90 days or more for a cold-stored can, 3 to 5 days for a purged crowler, and 1 to 3 days for a guest-filled growler.
- A crowler typically costs $1.15 to $2.20 in container, closure and label before beer, plus 2 to 4 minutes of bartender work.
- Bundles sell when they remove a choice. Discount packs built to clear slow stock tell guests which beers to skip.
Four gates, run in order
Most taprooms run this list backward. They copy a format from another brewery, order the equipment, then meet the license condition at the counter.
- License privilege.Your state alcohol beverage control board decides whether you may fill a container for a guest, which containers are allowed, and whether the beer may leave the premises. The sequencing logic behind that answer is set out in how a brewery and taproom license application is built.
- Building and equipment.Where does the fill happen, who performs it, and does that counter space exist?
- Bar time.Measure a fill during the Friday rush. A Tuesday afternoon measurement is fiction.
- Guest demand.Last, because the first three are constraints and this one is a preference.
A format that fails any gate is not an option, whatever it costs.
Shelf life and cost by format
Work happens
- Can from the cooler
- Packaging run, in advance
- Bottle from the cooler
- Packaging run, in advance
- Crowler, filled and seamed
- At the bar
- Growler, guest container
- At the bar
- Keg to go
- Cellar, with notice
- Mixed pack, built ahead
- Back of house
Typical shelf life
- Can from the cooler
- 90 to 120 days cold
- Bottle from the cooler
- 120 to 180 days
- Crowler, filled and seamed
- 3 to 5 days, up to 14 if purged and cold
- Growler, guest container
- 1 to 3 days, hours if unsanitized
- Keg to go
- Depends on handling
- Mixed pack, built ahead
- Its shortest item
Container, closure and label
- Can from the cooler
- $0.30 to $0.60
- Bottle from the cooler
- $0.50 to $0.90
- Crowler, filled and seamed
- $1.15 to $2.20
- Growler, guest container
- Near zero, plus cleaning
- Keg to go
- Refundable deposit
- Mixed pack, built ahead
- Case and divider
Bar time per sale
- Can from the cooler
- Very low
- Bottle from the cooler
- Very low
- Crowler, filled and seamed
- High
- Growler, guest container
- High
- Keg to go
- Moderate
- Mixed pack, built ahead
- Low
Those are typical ranges, not guarantees. Your own fills and supplier quotes will move them. Beer cost sits on top of the fourth column.
Which formats deserve shelf space at all is a lineup decision, worked through in the draft and packaged lineup.
Example: the conditions a state license attaches
California publishes each license type with its privileges. Growler sales appear there as a condition attached to a beer manufacturer license, not as a free-standing right. The California Department of Alcoholic Beverage Control license types page is the document you cite back to an inspector.
Get written answers to these questions before you order equipment:
Conditions a state license attaches
- Does my license privilege cover filling a container for a guest?
- Which container sizes and materials are permitted?
- How must the container be sealed and marked?
- Must we sanitize a guest's own container, or refuse it?
- Is there a per-person or per-day volume limit?
- Do we need a separate permit to resell another brewery's packaged beer?
Label approval and the timeline behind it
Beer packaged for off-premise sale is a labeled, regulated item. Federal labeling questions, growlers included, are answered on the TTB beer FAQs page.
A compliant malt beverage label states the brand name, the class and type such as beer, ale, lager or stout, the net contents, and the name and address of the brewer, bottler, packer or importer. Alcohol content is stated when the alcohol comes from added flavors or spirits. Those are the requirements in 27 CFR part 7, and they attach to the sealed container rather than to a growler filled behind the bar.
Every container also carries the health warning statement required by the Alcoholic Beverage Labeling Act, set out at 27 CFR part 16, with the words GOVERNMENT WARNING in capital letters and bold type: "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."
Approval runs on TTB Form 5100.31, the application for a Certificate of Label Approval. The COLA is required before the beer is introduced into commerce, and the approved certificate is what an inspector or a distributor asks to see.
Routine labels filed through TTB's COLAs Online system typically clear in 5 to 15 business days. A rejection restarts that clock. Some states add their own brand registration, which can take weeks more.
The chain is fixed: approval, then printing, then packaging, then your release date. Work backward from approval.
Label approval lead time
- FirstAsk federal regulator what label must carry
- ThenGet label approval for your product
- ThenOrder printed material
- ThenPackage the beer
- LastRelease date
Claims that need support
Everything on a container, a shelf tag or a board is advertising. The FTC advertising guide for small business requires claims to be truthful and supported.
Three takeaway claims need care:
- Freshness, because you are promising a taste weeks from now.
- Ingredient and origin, because both must match what you bought.
- Strength, which is a regulated statement and a marketing one at once.
Date conservatively. A container that tastes tired on its stated date costs more goodwill than a shorter window would.
Claims that need care
- Freshnesspromising a future taste
- Ingredient and originmust match what you bought
- Strength or contentmust match what you measured
- Datingbe conservative, shorter window is safer
Bundles that remove a choice
A bundle works when it removes a decision. The mixed four-pack, the growler with two glasses, the gift box with a preset lineup.
A discount pack built to move slow stock does the opposite. Guests read the contents as a verdict on those beers.
Ranking items by what they earn per bar minute is a separate exercise, done in products ranked by profit per bar minute.
The fill procedure, written down
The fill happens at your busiest moment, so write the process and train against it.
- Where empty containers live, and how a bartender reaches them without leaving the station.
- The fill itselfpurge, fill level, the same way every time.
- Sealing and marking, exactly as your state requires.
- What gets recorded, and where.
- What to do when a fill fails.
Step five carries the training weight. A failed fill during a rush is where an untrained person improvises, and improvisation produces the loss and the inconsistency. That belongs in the verification block of hiring and training the crew.
