COLA Expert's Help Needed

I have a question regarding label approval. If I want to bottle a private label for a wine shop under my bond, and we’re using the name of the wine shop as the brand name, but the trade name is the name of my winery, do I have to register the brand name as a dba, and submit the approved dba to the TTB? Or, can I use any brand name I want without registering it, as long as all of my trade names are approved dbas?

I rarely get stumped with COLA questions, but on this one, I think I know the answer, and I’m hoping I’m wrong and I don’t have to make another trip to City Hall to register another dba.

I had a compliance company walk me thru a similar situation recently, and there was no need for the full dba process on the local level. It was a relatively painless filing of TTB Form 5100.18 to amend your Basic Permit to add the new name to your authorized trade names. I had the terminology screwed up on my form. I thought, as I think you do also, that the company whose name was going on the front label would be the Brand name. They made me change the form so that the assumed name was another Trade Name, rather than a Brand Name. Jane Freimuth at TTB was surprisingly helpful in getting this sorted, and it’s worth giving her a call to get the terminology on the form straight.

Ed -

This should be no problem. As a private client importer, I hold 3,000+ label approvals. PM me if you need any help.

Kyle Smith
ITB

Thanks, Stewart and Kyle. Stewart reminded me that I should email my TTB contact, so I just did. I hope to hear from her on Monday. If I don’t, I might be emailing Kyle and contacting Stewart’s TTB person.

Thanks for discussing here. Keep us posted. I’d like to know what the process is as it could be a good option from time to time to label that way.

I got the reply I was hoping for from Kelly Hartley at the TTB today, very good news:



“Brand names do not need to be registered with TTB only trade names ( the name on the back of the label). As far as the state requirement to register the name, all states are different, so you may want to check with the county clerk.”


California doesn’t have label requirement beyond the TTB, so no trip to City Hall for me to register a new fictitious business name, (dba).