Brand Label Registration
Solicitors Must Register all Brand Labels with ATC
The Missouri Division of Alcohol and Tobacco Control (ATC) registers brand labels as Primary American Source of Supply (PAS) in compliance with Section 311.275, RSMo. Primary American Source of Supply means that only one solicitor may register to be the primary source for a brand and is the only company that may distribute this product in Missouri, through the appointment of Missouri wholesalers.
ATC has an Online System that manufacturers, solicitors, wineries and microbreweries must use to electronically submit new label registrations or to make changes to previously registered labels. Primary American Source of Supply applications are conditionally approved five (5) working days after receipt of a completed application. However, if you receive an email indicating “Action Required”, the conditional approval does not apply. ATC does not send automatic alerts for conditional approvals, but will email a permission to ship notification after the label has been processed and approved. If the application is denied, you will also receive notification.
This speeds up the approval process for Primary American Source and Brand Label Registration, thus, reducing wait time before products can be sold in Missouri.
Instructions for setting up permissions and user manuals are available on this page. If you need assistance with setting up permissions or electronically submitting brand label registrations, please email firstname.lastname@example.org or call (573) 751-4073; email email@example.com or call (573) 751-5450 or (573) 751-7891.
In order to ship alcoholic beverages to a licensed wholesaler in Missouri, a solicitor must be licensed with the Division of Alcohol and Tobacco Control using the Solicitor Application. For more information on alcoholic beverage licensing applications and forms, visit our Licensing page.
The solicitor must also comply with monthly alcoholic beverage excise tax reporting requirements. For more information on alcoholic beverage excise tax reporting requirements, visit our Excise Tax Reporting page.
To electronically register products the following information may be required:
- Approved TTB Certificate of Label Approval (COLA)
- Valid appointment letter from owner of product or certification of ownership of product. The term "primary American source of supply: shall mean the distiller, producer, the owner of the commodity at the time it became a marketable product, the bottler, or the exclusive agent of any such distiller, producer, bottler or owner, the basic requirement being that the nonresident seller be the first source closest to the manufacturer in the channel of commerce from whom the product can be secured by American wholesalers.
- Actual sample of the label corresponding with the TTB COLA. However, when TTB does not require a label approval when an allowable TTB change is made in non-mandatory text, illustrations, graphics, etc., ATC will accept an actual sample of the revised label.
- Wholesaler appointment and/or geographical agreement designating specific area within such wholesaler applicant is authorized to sell such brand.
- Notarized Lab Analysis if the alcohol content is not verified on the TTB Certificate of Label Approval (COLA).