The Alcohol and Tobacco Tax and Trade Bureau, god love ’em, continue to try and improve their processes and make things a bit easier on all of you when navigating their red tape for label approval. Here’s the deal on their latest update in COLA Online version 3.12.4.
Back up, what is COLA Online?
COLAs Online is TTB’s Web-based system for applying for a certificate of label approval (COLA!), certificate of exemption from label approval and distinctive liquor bottle approval.
Cool, so what’s new?
Three main areas have changed:
1. Removal of some data fields;
2. Addition of dropdown menus for selecting domestic appellations of origin for wines; and
3. Re-design of the formulas section.
These changes are part of the organization’s larger plan to reduce the amount of time it takes to obtain label approval from the TTB. Says the TTB:
“By decreasing the amount of information we require you to submit and adding tools to assist you with the accuracy of the information you supply, we are lowering the chances that we will have to send your application back for correction.”
Data fields being removed from COLA Online
The TTB no longer requires you to supply the following information when applying for a COLA:
- Alcohol content
- Net contents
- Vintage date (grape wine)
- Fax number
I know, I know — how will they ever contact you without your fax number? Well, allegedly, the TTB says “we rarely use that method to contact industry members any longer.” We remain skeptical.
Perhaps more importantly, the TTB evaluated what label information it will allow industry members to change as an allowable revision. Under this policy, industry members may change the alcohol content and net contents on a previously approved label without getting a new COLA.
As a result, you may legitimately have a COLA that covers a label where the information you originally supplied as the alcohol content or net contents no longer matches one or all of those statements on the actual label. Because of this, the TTB determined it could eliminate those fields from the application. Previously you had to enter the alcohol content, net contents and vintage date information as it appeared on the label, and if what you supplied did not match the information as shown on the label, the TTB sent it back for correction. Voila, your chances of receiving an error have been reduced.
Formula section re-design
Some of the most frequently cited reasons why COLA applications are returned for correction revolve around the formula requirements for certain alcohol beverages. Often industry members either are not aware that formula approval is required prior to applying for label approval, or the applicant fails to supply the correct formula approval information.
The TTB has added some questions and links to guidance in COLAs Online to help prevent you from submitting a COLA application if you are required to get formula approval before applying for label approval.
Currently, COLAs Online requires that both of the formula questions show the same response. The answer to the second question, “After reviewing the link do you require a formula?” will be used by the system to determine the answer shown for the first question, “Are there flavors and/or coloring added to your product?” regardless of how you answered the first question. The TTB is working to revise this situation, but in the interim, please do not change the answer to the first question so that is does not match the answer to the second question, even if it is no longer accurate.
For example, if you answer “Yes” to the question, “Are there flavors and/or coloring added to your product?” but then review the documentation at the link and determine that a formula is not required for your product and you answer “No” to the question, “After reviewing the link do you require a formula?” COLAs Online will automatically change the answer to the first question to “No.” Please do not change the answer to the first question back to “yes,” even if you have added flavors and/or coloring material to your product, as you will get an error message when you attempt to go to the next step.
The same is true if you answer “No” to the first question and “Yes” to the second question. COLAs Online will automatically change the first answer to “Yes” and you will get an error message if you change it back to “No.”
Get it? Good. Since you obviously love reading about federal label approval, here is another thing to read.