Know the Rules — Missouri simplifies brand label registration

As of March 2, 2020, the Missouri Division of Alcohol and Tobacco Control (ATC) has updated its primary American source of supply brand label registration requirements.

This is good news for producers and suppliers of beverage alcohol products since these changes reduce the number of circumstances that require submitting a new registration for label revision. Similar to the Alcohol and Tobacco Tax and Trade Bureau (TTB) allowable revisions, the state of Missouri has indicated a list of conditions that detail when an already approved label is acceptable and re-registration is not required.

For example, producers no longer need to re-register if an already approved product only has a new proof or age/vintage. Also, under Missouri’s new rules, if you’re creating a gift pack with multiple products and all of the individual products are registered, you don’t have to submit a separate registration for the gift pack.

This makes doing business easier for those who manage product registrations and often wear many other hats within the business. Below is a summary of the new rules; you can find full details here.

• Registration of each proof and/or age of an intoxicating liquor is no longer required. Sales are limited to the alcohol content allowed by the license type.
• Specialized names no longer need to be registered once the TTB Certificate of Label Approval (COLA) has been approved by ATC for the product.
• Label revisions are not required to be submitted for graphic, color, or font changes, but they are required for class and type changes.
• Gift packs, combo packs, and value-added packs (VAPs) don’t have to be registered separately, but the individual products within them do.
• Promotional labels, like holiday labels, don’t have to be registered once the COLA has been approved.
• Label upload requirements vary based on COLA requirements (see rule details for full information).
• A wholesaler appointment letter and permission-to-ship letter corresponding to the active brand number are still required. 
• The primary American source of supply is responsible for moving duplicate brand numbers in the ATC online system to an inactive status.

These rules and regulations can be overwhelming. If you still have questions, the Avalara team as the expertise and tools to help you untangle them, in every state. You can reach us at 877-855-9956 or bevalcinfo@avalara.com.