TTB label approvals, or COLAs as the lingo goes for industry insiders are a topic that generally causes those of us who deal with their submission and approval to roll our eyes and have no shortage of “war stories” to share of our experiences with them over the years.
Despite our often frustrated view of the label approval process, the TTB has made great strides in streamlining the whole submission/approval process over the last few years. In September 2014 they again updated their list of allowable label revisions. This updated list has meant that wineries and wine cellars get to save themselves some time and potential lost sleep by NOT having to submit for a new label approval (COLA). This updated list of allowable label revisions applies to any wines that your site (which means your TTB permit) has previously obtained a COLA. It is well worth the time of winery staff to be familiar with this list, so they then know whether or not they need to bother with submitting a new COLA for wines that they bottle every year.
This latest update from the TTB related to label approvals now means that winery or wine cellar staff can incorrectly complete their label approval applications & still have them approved! The TTB just announced that they will now allow 3 fields on the application to NOT match the actual data on the wine label(s).
Those 3 application fields are: net contents, alcohol content & vintage.
So what does this mean? If you submit a label approval for a wine and the information you put in any of the above fields of the COLAs online application (net contents, alcohol content & vintage) does NOT match what appears on the label files that you upload, then the TTB specialist viewing the application will still go ahead and view your label files since those 3 fields are all part of the list of allowable changes. As long as all other fields on the application match the label files, and the balance of items on the actual label(s) are all compliant they will approve it.
A more specific example of this would be if I submitted a label approval application with the following: the net contents field listed 375ml, the alcohol content field listed 14.5%, and the vintage field listed 2013. However, the label files that I uploaded were printed with: 750ml, 13.8%, and 2014. These 3 non matching fields are all examples of allowable label changes, so the TTB specialist would still be able to approval this application, provided the rest of the fields and items printed on the labels were correct and in compliance.
To view the TTB announcement summary follow this link and you’ll see it in their Announcements section on the lower right side: