Label law for a commercially sold bottled product

[sagedeer]

Hey I am a small kombucha (fermented tea) start up and am using 100% reused beer bottles. Since it's a lot of work to clean the labels off, I was wondering if I could just rubber band my label to the neck/body of the bottle? Does anyone know the laws? Or is a label for bottled products required to stick to the bottle?

Thanks!

Sage

 

[IXVolt]

Not sure about your legal question, but as a consumer if saw a bottle with a rubber band holding the label on I would certainly choose a different brand. You might want to rethink this.

 

[DromJohn]

27 C.F.R. §16.22 General requirements.
(a) Legibility. (1) All labels shall be so designed that the statement required by §16.21 is readily legible under ordinary conditions, and such statement shall be on a contrasting background.

(2) The first two words of the statement required by §16.21, i.e., “GOVERNMENT WARNING,” shall appear in capital letters and in bold type. The remainder of the warning statement may not appear in bold type.

(3) The letters and/or words of the statement required by §16.21 shall not be compressed in such a manner that the warning statement is not readily legible.

(4) The warning statement required by §16.21 shall appear in a maximum number of characters (i.e., letters, numbers, marks) per inch, as follows:

Minimum required type size for warning statement Maximum number of characters per inch
1 millimeter 40
2 millimeters 25
3 millimeters 12
(b) Size of type. (1) Containers of 237 milliliters (8 fl. oz.) or less. The mandatory statement required by §16.21 shall be in script, type, or printing not smaller than 1 millimeter.

(2) Containers of more than 237 milliliters (8 fl. oz.) up to 3 liters (101 fl. oz.). The mandatory statement required by §16.21 shall be in script, type, or printing not smaller than 2 millimeters.

(3) Containers of more than 3 liters (101 fl. oz.). The mandatory statement required by §16.21 shall be in script, type, or printing not smaller than 3 millimeters.

(c) Labels firmly affixed. Labels bearing the statement required by §16.21 which are not an integral part of the container shall be affixed to containers of alcoholic beverages in such manner that they cannot be removed without thorough application of water or other solvents.

 

[sagedeer]

IXVolt - yeah it might not look that nice, but since we're so small and selling in person directly to consumers right now I don't think it would be that big of a deal. Maybe. It would be a temporary thing anyhow until we get some more equipment

DromJohn - This kombucha is legally non-alcoholic (there is a slight amount), so I wonder if it's the same for non-alcoholic beverages? I wonder what the law is for soda companies...

 

[BlkWater_brewer]

Seriously, remove the label, selling in person or not. Just soak them in ammonia and water for 20-30 minutes. I have not found a label that won't just peel off. I take them and just make a collage out of the various bottle labels. Stay away from the bottles with foil, more trouble than they are worth. Appearance is everything - why ruin your product by using an old labeled bottle. I know I would not even consider drinking something in such a bottle. Why do you think marketing is such an important aspect of any type of sales? If your drink is good enough to sell, it's worth the effort, believe me. Good luck

 

[Mike_kever_kombi]

I think all the best brews come from places that can't remove previous labels, f#ck why limit yourself to just beer bottles? You can use old snapple bottles, salsa jars, and instead of growlers just use milk jugs (no need to rinse).

I also like going to restaurants where the cockroaches just run rampant.

Seriously, if you are not a troll, then you need rethink your business plan, because you are grade A fail.

 

[Shakybones]

It's Kombucha. Why would anyone be worried about cleanliness?

http://en.wikipedia.org/wiki/Kombucha
"Drinking kombucha has been linked to serious side effects and deaths, and improper preparation can lead to contamination."

 

[TheCanisDirus]

It's Kombucha. Why would anyone be worried about cleanliness?

http://en.wikipedia.org/wiki/Kombucha
"Drinking kombucha has been linked to serious side effects and deaths, and improper preparation can lead to contamination."

Mmmmmm....

Botulism!

 

[jtratcliff]

warm oxyclean soak... labels slide right off.... Quick brush with a nylon scrubby to remove residual glue, and rinse. Easy Peasy. Has the benefit of cleaning out any scum from inside as well.

I agree with the others, though. No rubber bands.

 

[icebob]

You say you're a small startup, and with this mindset, you will never go to the next level... come on dude, be proud of your stuff...Oh, btw, starting a business is a LOT of work.... just saying...

 

[MrFoodScientist]

Code of Federal Regulations, Title 21, Chapter 1, Subchapter B, Part 101: Food Labeling

You'll find all the information you need in there. You'll find the information for what is required as far as typeface sizing, specific information that should appear on you principle display panel, information about nutrient content and health claims, typeface and border sizing for your nutrition facts panel, safe handling statements and the like.

Also not sure if kombucha is subject to a required HACCP plan like juices. That's not part of labeling, so it would be found in a different part of Title 21. Regulations have changed recently, so you definitely want to make sure you are up to date on what is/isn't required. I hope you're fluent in legalese, because nothing will confuse you or put you to sleep faster than reading the CFR.

I thought that I had seen somewhere in there something similar to what was posted above from Title 27 about labels firmly affixed, but now I can't find it. Good luck, I hope it works out for you.

 

[sagedeer]

Thanks for the info everyone. This question came up because I've seen some local businesses putting things in mason jars with rubber bands holding on the labels, but their product was not preserved or pressurized in any way, so I imagine it is different for them. Just exploring options. Starting a business is a lot of work, but we're already in the green after two months so I think I'm doing pretty well

It's legal to wash and reuse bottles, just most businesses don't. I've become quite good at a thorough cleaning process for bottles, including soaking and sanitizing them. With the product being acidic enough that botulism cannot survive, it's actually really safe, and on top of that saves quite a bit of money, is way better for the environment than recycling, and is fun for consumers, especially since our market is the health/environment conscious. Articles talking about the dangers of kombucha generally are referring to a case where the FDA made mention that two people who died of unknown causes both made their own kombucha, but when the drink was tested no ill organisms were found. Media sensationalism bull****. Please do your research and don't just quote wikipedia. Outside of that I imagine people don't care for their culture properly or drink too much (it is most often used as a digestive aid, and that can make you feel really funny).