What COLACheck cannot do.

It only sees the image

Several requirements are physical. An image cannot settle them:

• Type size. Mandatory text must meet minimum heights in millimetres. If you supply the physical dimensions of the label we can estimate those heights from your artwork, but an estimate taken from an image is not a measurement of the printed container.
• Legibility and contrast under ordinary viewing conditions.
• Whether the label is firmly affixed, and whether it can be removed by soaking — a requirement under Part 7.
• Actual container volume, as opposed to what the label claims.

On type size specifically: where you give us the label’s width and height, we read the text on your artwork and report its height in millimetres against the threshold that applies. Two things stop that from being conclusive. The character outlines we measure are slightly taller than the letters inside them, and any margin left around the label in your image stretches the scale — both errors make text read larger than it really is. A measured height is therefore always returned as Review, never as Pass, and the figure is only as accurate as the dimensions you enter. Estimated dimensions produce estimated millimetres.

It cannot verify facts that aren’t printed on the label

Some of the most consequential requirements turn on facts about the liquid, not the artwork. These are always returned as Review, never as Pass:

• Sulfur dioxide at or above 10 ppm, which is what triggers the sulfite declaration.
• Grape percentages behind an appellation of origin — 75% for a country, state or county; 85% for a viticultural area; and for multicounty or multistate appellations, all of the fruit from the named areas with each percentage stated on the label.
• Vintage percentages — 95% for a viticultural area appellation, 85% otherwise.
• Whether "Estate Bottled" conditions are actually met.
• Whether a stated age, alcohol content, or class designation is truthful.
• Whether colorings or additives requiring disclosure were in fact used.

A Review is not a soft pass. It means we cannot answer, and you must.

It checks federal requirements only

Nothing here covers state labeling law, state registration or franchise requirements, container-deposit marking, or local rules. Several states impose requirements beyond the federal ones. A federally compliant label may still be non-compliant in the state where you intend to sell it.

It does not cover everything TTB looks at

Out of scope: formula and lab sample approval, FDA requirements, trademark conflicts, distinctive liquor bottle approval, and the accuracy of your COLA application form itself.

The checks are derived from the regulation, not a substitute for it

The requirement list is written and maintained by hand from 27 CFR. It reflects human judgment about what matters and how to state it, and it can be incomplete or wrong in ways an automated system would not detect. The regulation itself always governs.

It is AI-based, and AI misreads things

Analysis is performed by a machine learning model. It can misread stylized typefaces, foil, embossing, curved or angled photographs, low-resolution scans, and text in languages other than English. It can also be confidently wrong. Upload the highest-resolution artwork you have, and treat every finding as something to verify rather than something to act on unread.

It is in beta and has had limited real-world testing

COLACheck is new. It has not been validated against a large corpus of previously approved and rejected labels. Findings may be incomplete or incorrect. It is free during this period, and the absence of a fee reflects the absence of a warranty.

This is not legal advice

COLACheck provides informational guidance based on published TTB regulations. It does not create an attorney-client relationship and is not a substitute for professional advice. For complex submissions, unusual label designs, or anything with money riding on it, consult a qualified attorney or contact TTB directly at 1-866-927-2533 or alfd@ttb.gov.