By Michael Kaiser
The Alcohol Tobacco Tax and Trade Bureau has just announced a few changes for submitting Certificate of Label Approvals (COLAs) and Formula Approvals.
As many of you probably noticed it is taking longer than normal for COLAs to be reviewed. The current average is around 20 to 25 business days, which works out to close to six weeks. The TTB came out with the following statement today:
COLA and formula reviews will continue to be conducted in as timely a manner as possible. To achieve that goal, we will continue to review COLA and formula applications in the order they are received. However, to reduce review delays on these applications, we will no longer be accepting “Expedite Requests” or "Informal Reviews,” effective immediately. As we are experiencing considerable increases in the number of applications received, you should allow adequate time for a 90-day application review process within your business plan and anticipate that we may require you to make revisions to your labels or formulas.
Now, this does not mean that it will take 90 days for your label submission to be approved, but what it does mean is to allow 90 days for any issues that may come up with the label. The TTB is currently understaffed, and with the current Federal hiring freeze, they cannot hire new staff and if someone leaves the agency they are not replaced.
What is of particular concern is the suspension of "Expedite Requests". In the past, with proper documentation, the TTB would expedite the review of a particular label(s). Label approvals could be turned around in less than a week. Now a winery has no recourse for an expedited label review if an unforeseen rejection occurs.
TTB is strongly encouraging people to use the COLAs Online system. Online applications are reviewed in half the amount of time that paper submissions are. Because of the amount of labels submitted and the staffing issues at TTB, it is currently taking around 10 business days for COLAs to be reviewed online.
If you are a WineAmerica member and are currently using COLAs Online or want to switch to that form of COLA submission, I am always more than happy to review the label before it is submitted.
If you have any questions about this TTB announcement please contact me at email@example.com or at 202-783-2756.
To read the notice from TTB, please go here: http://www.ttb.gov/labeling/label-formula-application-adjustment.shtml