Yes — TTB requires a separate Certificate of Label Approval (COLA) for each distinct label variant of an imported malt beverage. This includes different package sizes, label designs, and seasonal or limited-edition releases. Importers should build COLA lead times into their procurement calendars, as approval processing can take several weeks.

TTB formula approval is required when a beer contains ingredients beyond the standard water, malt, hops, and yeast — such as fruit, spices, honey, or other adjuncts. A COLA, by contrast, is required for all imported malt beverages regardless of ingredients. Products needing formula approval must receive that approval before a COLA can be issued, adding a sequential step to the pre-import compliance process.