Why You Should be Submitting Your COLA’s Online

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. 

TTB Updates Processing Times for Label Approvals

The TTB has updated their system for current label approval processing times.  Their  Current Label Processing Times chart shows up-to-date processing information for applications.  Use the chart to estimate when your application is likely to be processed.  The chart can be viewed here:

Current Label Processing Times

If you have any questions please contact Michael Kaiser at mkaiser@wineamerica.org.

WineAmerica Signs Letter to Promote Passage of the Farm Bill

WineAmerica has signed on to the following letter promoted by the Specialty Crop Farm Bill Alliance (of which we are a member) to promote passage of the Farm Bill.  Congress is heading into a month long recess after today and will not reconvene until after Labor Day on September 3, leaving only 27 days to either pass a new version of the Farm Bill, or sign an extension of the current bill, which expires at midnight on September 30.  WineAmerica strongly supports the passage of a new bill, rather than an extension due to the lack of specialty crop funding in the existing extension of the 2008 Farm Bill.

America’s agriculture, conservation, rural development, finance, forestry, energy and crop insurance companies and organizations strongly urge you to complete a Farm Bill as soon as possible. This important legislation supports our nation’s farmers, ranchers, forest owners, food security, natural resources and wildlife habitats, rural communities, and the 16 million Americans whose jobs directly depend on the agriculture industry.

For decades, the threat of reinstatement of the long-outdated policies of the 1938 and 1949 Acts have served as strong motivation for Congress to enact new farm bills. Repealing those Acts and making the 2013 farm bill commodity title permanent law could make it difficult to generate sufficient political pressure to adjust the commodity safety net provisions should conditions in production agriculture change. As recently as last December, the threat of reverting to permanent law was the critical element that forced the last Congress to pass an extension of the current farm bill when it proved impossible to complete action on the new five-year farm bill – an action that provided important safety net programs for 2013 and ensured Congress would have time this year to consider comprehensive reforms that will contribute billions to deficit reduction.

We also are concerned that if the 2013 farm bill’s Title I is made permanent, other important farm and rural programs covered in other titles would risk not being reauthorized if the bill expires after five years.  If this should occur and we revert to “permanent” law, then programs covering conservation, forestry, research, energy, rural development, specialty crops, trade, etc., could be left to the will of the appropriations process, likely with limited funding and little opportunity to updated or adjusted to meet changing needs in agriculture and rural communities.

And we also fear that a Farm Bill without a meaningful nutrition title will make it difficult, if not impossible, for the House and Senate to reach agreement on a final version that can be signed by the President.  We urge you to move forward on a unified farm bill that continues the “marriage” between the nutrition and farm communities and our constituents.  Developing and adopting comprehensive farm legislation has been an effective, balanced arrangement for decades that has ensured all Americans and our nation benefit from the farm bill.

We stand ready to work with you to complete passage of the new five-year Farm Bill before the current law expires again on September 30, 2013.