Beer label approval for a Montana brewery

The two approvals, and the third surprise

A Montana brewery can need two label approvals for one can: a federal Certificate of Label Approval and a Montana label registration in TAP. A high-alcohol beer adds a third review.

The federal certificate, called a COLA, comes from TTB through COLAs Online, and there is no fee to apply. The Montana registration covers beer sold and shipped into the state.

The surprise is the in-house rule: a domestic brewery's beer from 8.75 percent alcohol up to under 14 percent must be approved by the Montana Department of Revenue even if it is only served in your own sample room.

There is no fee to apply for a Certificate of Label Approval through TTB's COLAs Online system. — Alcohol and Tobacco Tax and Trade Bureau, retrieved 2026-09-29

The federal COLA: when it is required

The federal rule has a clean trigger: you must obtain label approval prior to bottling if you are shipping out of state. Beer sold only inside Montana does not carry the same federal trigger.

You may file through COLAs Online after TTB has approved the Brewer's Notice, or on paper using TTB Form 5100.31. Once registered in the online system, an application is submitted electronically, with no forms to sign.

Plan the launch calendar around the approval, not around the brew day. The certificate has to exist before the labeled beer leaves the building, not before the beer exists.

TTB F 5100.31A brewer must obtain label approval prior to bottling if shipping out of state, filed electronically through COLAs Online or on TTB Form 5100.31. — Alcohol and Tobacco Tax and Trade Bureau, retrieved 2026-09-29

Getting set up in COLAs Online

COLAs Online needs an account, and the account needs a brewery behind it. You must have a permit number before you can register for the system.

Registration can take TTB a few days, and account setup for a new brewery is a step to calendar, not a click. The permit number comes from the Brewer's Notice guide. One account works for COLAs Online and Formulas Online together.

Some products need formula approval before the label application. A flavored beer or one with nonstandard ingredients may need the formula step first, which is one more reason the label calendar starts early.

A brewery must have a permit number before it can register for COLAs Online, it may take TTB a few days to set up an account, and some products require formula approval before a label application. — Alcohol and Tobacco Tax and Trade Bureau, retrieved 2026-09-29

The Montana registration: all labels, before sale

Montana's rule is broader than the federal one. All beer labels must be approved by the Montana Department of Revenue before selling and shipping into Montana.

For a Montana brewery, that reads as a registration step on every packaged release. You register the labels through TAP, the same TransAction Portal that holds the license and the tax returns.

Treat it as part of the release checklist, next to the federal certificate. A label approved federally and registered in TAP is release-ready on both sides.

All beer labels must be approved by the Montana Department of Revenue before selling and shipping into Montana, and labels may be registered for approval through the TransAction Portal. — Montana Department of Revenue, retrieved 2026-09-29

The 8.75 percent rule that reaches the taproom

Here is the rule that catches new brewers: all beer with an ABV of 8.75 percent and over to under 14 percent produced by a domestic brewery must be approved by the department, even if the beer is only served and sold in your sample room.

A barrel-aged stout at 9.5 percent that never leaves the building still needs state approval. The tap list is inside the label rules, not outside them.

Check the strength before the release date. The band starts at 8.75 and runs to under 14, so a 14 percent beer is outside this particular requirement and subject to the general label rules instead. What the sample room may then pour is on the taproom page.

8.75% ABVAll beer with an ABV of 8.75 percent and over to under 14 percent from a domestic brewery must be approved by the department even if only served and sold in the sample room. — Montana Department of Revenue, retrieved 2026-09-29

Labels, brands and the trademark question

Label approval is not trademark clearance. A COLA says the label meets the federal labeling rules; it does not say you own the name.

Federal trademark registration runs through the United States Patent and Trademark Office, which is a separate system from both TTB and the Montana Department of Revenue.

On the state side, the Secretary of State's fee schedule carries name registration at $10 a year for foreign entities, while a Montana business name search runs through the same office. The brand decision deserves a search before the label art is final.

$10 a yearMontana's Secretary of State fee schedule lists registration of a name at $10 a year and renewal of a name registration at $10 a year for foreign filings. — Montana Secretary of State, retrieved 2026-09-29

Running label approvals as a pipeline, not a scramble

A brewery that releases monthly runs label approvals as a pipeline. Each release gets its federal certificate if it ships, its TAP registration, and the 8.75 percent check on strength.

The recordkeeping rule applies here too: federal brewery records, including those behind label and removal data, are preserved for at least three years.

Keep one register of every label, its ABV, its federal status and its Montana status. When the renewal season arrives in June, that register is the fastest compliance document you own. The surrounding calendar is on the yearly renewals page, and the license behind the labels is on the Montana license guide.

3 yearsFederal brewery records must be preserved for not less than three years from the date of the transaction or the date of the last entry, whichever is later. — Alcohol and Tobacco Tax and Trade Bureau, retrieved 2026-09-29

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