Craft breweries not labeling net contents

Possibly because of this exception to the regulation?

 

1. I've not noticed. To be honest, I rarely look at labels unless it's exceptionally neat art.
2 and 3 - could be Jesskidden's answer.

 

Were there stamps on the bottom of the cans indicating volume/ABV? I remember a brewer telling me recently that the laws have shifted slightly around labeling, affording brewers the chance to have less on the label as long as they stamped that info on the bottom.

 

Did you purchase directly from the brewery, or in distribution? I know of at least one brewery who sold completely blank cans over the bar for small batch releases.

 

Many states do not require you to get COLA to distribute within your own state. So unless the brewery is distributing outside of their own state, the COLA would not be required.

 

Could it be due to variance in fill level? Maybe they're worried that low fill cans could throw off their volume measurement and thus make the label considered false or misleading.

 

Yeah, the regulations are pretty confusing:

According to TTB Ruling 2013-1

The Alcohol and Tobacco Tax and Trade Bureau (TTB) has been asked to clarify whether brewers are required to obtain a certificate of label approval for domestically bottled malt beverages that will be sold exclusively in the State in which they were bottled. The regulations implementing the Federal Alcohol Administration Act do not require a brewer to obtain either a certificate of label approval or a certificate of exemption for a domestically bottled malt beverage that will not be shipped or delivered for sale or shipment into another State. Regardless of whether a domestically bottled malt beverage will be sold in interstate commerce, brewers must comply with all applicable marking, branding and labeling requirements under regulations implementing the Internal Revenue Code of 1986 for all beer removed from the premises, and must comply with the health warning statement requirements imposed by the Alcoholic Beverage Labeling Act with regard to alcoholic beverages manufactured or bottled for sale or distribution in the United States.

We remind brewers that they must comply with the marking, branding and labeling requirements for all beer removed from the premises under regulations implementing the Internal Revenue Code of 1986. See 27 CFR part 25, subpart J.
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Title 27 › Chapter I › Subchapter A › Part 25 › Subpart J ›
§ 25.142 Bottles.
(a)Label requirements. Each bottle of beer shall show by label or otherwise the name or trade name of the brewer, the net contents of the bottle, the nature of the product such as beer, ale, porter, stout, etc., and the place of production (city and, when necessary for identification, State).
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Have you checked the actual COLAs (if they exist) for those unnamed brewers' beers? Often exceptions or "use-up" permission are noted on the actual approval.

 

I really don't look that closely at the "net contents." I'm more interested in the style and the date.

 

With 69 (as of May 2017) inspectors regulating over 20,000 industry members, the TTB has a lot more pressing matters than a brewery releasing a beer without net contents listed. Not saying the brewery shouldn't do it... They certainly should, but it's not the end of the world and would likely result in a very light slap on the wrist by the local and/or federal regulators.

 

I care more about dating cans and bottles.