Craft beer label turn times should be improving, according to the Alcohol and Tobacco Tax Bureau (TTB). More specifically, the TTB has improved the certificates of label approval (COLA) paper application process in order to quicken turn times. The electronic submission process will remain as is (because it is already electronic, and therefore, adequately speedy).
For those of you still submitting your applications in paper form (about 90 percent of COLAs are received electronically … so get with it!) here is a long-winded break down of what has changed and why it should increase the turn-time on your label application approval.
Hold up, I need some background first. What are you talking about?
The Federal Alcohol Administration Act (FAA Act) provides for the application for and issuance of COLAs for wine, distilled spirits and malt beverages sold or shipped in interstate or foreign commerce and authorizes the Secretary of the Treasury to prescribe regulations for the labeling of such products. The TTB administers the regulations, which are meant to prohibit consumer deception and the use of misleading statements on labels, and ensure that labels provide the consumer with adequate information about the identity and quality of the product.
TTB receives applications from industry members either electronically, through the COLAs Online system, or in paper form on TTB F 5100.31, “Application for and Certification/Exemption of Label/Bottle Approval.” About 90 percent of COLA applications are filed and processed electronically. However, TTB said it is seeking ways to improve the turnaround time for paper applications that are filed by mail or hand delivery.
Wait, so the paper process has improved?
COLA applications received in paper format are currently processed in paper format. Under the current procedure, once TTB completes its evaluation of a paper application, it will mail a copy of the application back to the industry member at the address listed on the form or, if a third-party representative personally delivered the application to TTB, a copy of the application is provided to the representative for personal pick-up. If the application is approved, TTB then scans the approved paper forms into electronic format so that the approved labels can be included in the Public COLA Registry.
In order to improve the paper COLA application review process, the TTB will streamline this administrative procedure by using a more efficient electronic process for COLA applications that are submitted in paper format. Beyond the turnaround time, the average processing time for malt beverage applications is currently 10 days.
Exactly what is different?
The tracking and evaluation of the paper COLA application is now automated. The TTB will scan the paper COLA applications after receipt and process them electronically. If the COLA application includes an email address, applicants will be notified of approval via email instead of snail mail, hand delivery, Pony Express or “Game of Thrones” raven.
Not only will there be emails, there will be encrypted emails, sent to all emails on the application. This encrypted email will include a low-resolution copy of the application and information on where to access the high-resolution version. It may also include qualifications on your COLA approval.
If the application is rejected, the email will include a high-resolution copy of the application, a list of reasons why a rejection was issued and the steps to follow in order to correct and resubmit the application.
In summary, if you provide an email address, there is no more paper involved in this equation. Notification of final status for those who provide email addresses will arrive within one business day of the TTB’s determination.
“Upon implementation, electronically processed COLA applications will result in efficiencies to TTB and be less costly to American taxpayers,” the TTB stated in its explanation.
Hurray! We’re all rich!
When does this start again?
It’s happening right now! This went into effect on Feb.1.
This seems simple enough, how can I still get screwed?
In order to receive email notifications from TTB, you must provide an email address on each paper application that is submitted. So, if you provide an email address on just one application, but you submit multiple applications, then you will only receive an email notification regarding the application on which you provided an email address. Of course.
Also, to read these encrypted emails, you will need to register your email address. The instructions for doing so are revealed when you click “open the message” within the email. These emails also expire on a specific date and time – but if this goes in your spam folder and you miss the date somehow, this will not affect your COLA status.
What information will TTB include in the email?
Emails for approved COLA applications will include:
- An attachment containing a low resolution copy of the approved COLA;
- A list of any qualifications that have been placed on the approved COLA; and
- Instructions for where to access a high resolution (quality) image of your approved COLA.
We will continue to place a copy of the approved COLA in the Public COLA Registry. The approved COLA will be available on the Public COLA Registry within 10 days of the approval date.
Emails for rejected applications will include:
- A list of the reasons that we rejected the application;
- A list of instructions specifying how to correct and resubmit the application; and
- An attachment containing a high resolution copy of the rejected application.
If for some reason the only technology I own is a VCR, and I don’t have an email address … or if I am so distrusting of the government with my personal info that I refuse to give them my email address … what then, huh?
If you choose not to provide an email address on your application (or forget), your application will still be scanned and processed electronically by TTB because they are so high tech now. However, they will play by your rules and mail everything like they did previously. Obviously, these paper-based responses will take significantly longer for you to receive than an electronic response would.
What about applications submitted by third-party representatives, smart guy?
Beginning with applications received after Feb. 1, 2013, any paper applications that contain email addresses will be returned to those email addresses, even if the original application was personally delivered by a third-party representative. This is the case even if the email address belongs to the applicant and the label is submitted by a representative. Accordingly, if the applicant wishes to have replies sent to the representative rather than the applicant, the representative’s email address should appear on the paper application rather than the applicant’s. On the other hand, if the applicant wishes to receive responses, then the applicant’s email address should be listed on the form. Only one email address may be listed on the form.
Ugh, I still have 1 million questions. Do you have a couple hours?
No. But the TTB does. If you have questions concerning any of this new information, or anything at all pertaining to the COLA process, please contact the Advertising, Labeling and Formulation Division at [email protected] or call toll free 1–866–927–2533. Craft brewers, use option 4. And there is always the COLA frequently asked questions, which contains much less silliness and much more valuable information.