By Michael Kaiser, Director of Communications and Regulatory Affairs
One of the most important things a winery does is design its labels, but as you know, every label needs to be compliant and needs to be reviewed by the TTB. Currently it takes close to two months to get a Certificate of Label Approval (COLA) approved. What used to take two days is now taking 40 days. This is due to a variety of factors. TTB has faced budget cutbacks in recent years, leading to a reduced staff. The industry has also grown exponentially, leading to increasing amounts of COLA submittals. The TTB has tried to remedy this by allowing for certain revisions on labels and not reviewing items such as type size, but the labels keep coming in and there doesn’t seem to be any indication the submission rates will slow down.
TTB has equalized COLA submission times for online and paper submittals. The initial review of a COLA now takes the same amount of time regardless of how it is submitted. The difference is what happens if there is a problem after the initial review. First, a COLA submitted online weeds out application errors. A COLA cannot be submitted online if the application is not complete. But, if a COLA submitted online does have an error, it will be emailed to the submitter as “needing correction”, rather than being outright rejected. The submitter is given three chances to fix any error before an outright rejection. When the COLA is corrected, it is then given priority for review, and odds are, your corrected label will be approved within 24 hours.
If the COLA you submit on paper has an error, you face serious delays. If there is any error, no matter how small, the COLA needs to be completely resubmitted—meaning will be treated as a completely new COLA submittal. No preferential treatment is given. Your label will take another 40 days to be reviewed,. One error can cause the submittal process to strech from 40 days to three months.
WineAmerica assists with online COLA submittals by doing an initial review of your label before it is submitted. We work closely with the TTB to stay up today on the changes in their COLA registration. To help ensure streamlined assistance, we will proof the label and let you know if you need to make any changes before beginning the submittal process. WineAmerica will continue to assist with paper submittals, but we strongly recommend our member wineries utilize the online process.
If you have any questions about how to sign up and use COLAs Online please don’t hesitate to contact us.