Each year the TTB conducts its Alcohol Beverage Sampling Program where it randomly purchases products to assess whether their labels comply with federal regulations and to test whether their contents comply with the information identified on the label (e.g. that the beer in a bottle labeled as 5.0% ABV is within the applicable tolerance, which is generally ± .3% ABV for beer).
The TTB sampled 450 products and found that 152 of those products were non-compliant. The most common deficiency for malt beverages and wine was that the information on the label did not match the approved COLA due to changes that were not allowable revisions. A handful of the samples were missing mandatory labelling information. Failing to comply with labelling requirements is grounds for fines and penalties. However, these types of errors certainly can be avoided by consulting with an attorney familiar with the applicable labeling requirements. NMM regularly counsels brewers, distillers and wineries on labelling issues for alcohol products placed into interstate commerce. Also, keep in mind some states have their own labelling requirements (e.g. ABVs are not required for beer by the TTB, but it is a requirement in many states).