I saw this came up in the Societe tasting room thread, but I figured I'd give it the full treatment.
The CA ABC held a workshop yesterday for Southern California craft brewers, and the head of the ABC, Jacob Appelsmith, addressed a couple of specific issues in his introduction. One of those was growlers.
He said breweries (type 23, i.e. Small Beer Manufacturers) can fill any sealable vessel as a growler as long as they can cover up any previous label and convey the mandatory label information (name of brewery, city and state where it was brewed, name of beer, and ABV if the beer is over 5.7%. I believe the surgeon's general warning is a TTB requirement). Breweries must get label approval for however they choose to convey that information, even if it's just a sharpie on a piece of duct tape (they showed us several examples of label approvals that were just handwritten name tags from Office Depot). He also said you could theoretically have a common, blank growler (except for the surgeon's general warning, I imagine), if you could legibly fit all the mandatory information on a screw cap. A growler coozie with the mandatory info would also work if it covered everything.
There was lots of murmuring and confused looks in the room, and a couple of people asked questions to clarify. He admitted that there had been confusion within the ABC about it, and said local offices should now be on the same page. (Quite a few brewers told me afterward that they were specifically instructed by local ABC officers that they could only fill their own growlers.)
I talked to Tom McCormick, head of the CA Craft Brewers Association, and he said the ABC issued a reinterpretation of the code about 6 months ago that spelled this out. He said he's going to make an effort to make sure everyone knows about it.
This is obviously welcome news. As for Modern Times, I'm still planning to offer the standard 64oz. glass growler with our logo for interested parties, but I'm going to look into the screwcap idea and stickers.
Cheers!