On the issue of Certificates of Label Approval (COLAs), the Alcohol and Tobacco Tax and Trade Bureau (TTB) is finding itself caught between a rock and a hard place. The rock is their funding, including dwindling budgets each year, and concerns over furloughs, government shutdowns, and long term sequestration given an inept and unpredictable Congress. The hard place is an industry that is pumping more and more products into the marketplace and a need to get products to market quickly because of a dizzying pace of innovation.
The result of this squeeze is longer approval times for new COLA applications. Even though TTB has made great strides and a substantial number of changes to streamline the COLA filing process, current COLA processing times are 38 days for distilled spirits labels, 12 days for malt beverage labels, and 25 days for wine labels.
TTB has also signaled that they would like to make even more changes to the COLA process. As we discussed on a panel at the National Conference of State Liquor Administrators (NCSLA) Annual Conference this summer in Hawaii, TTB would like to continue to explore substantial ways to overhaul the label pre-approval process, including potentially moving to a “deemed-approved” process with automated decisions for certain eligible labels and a shift to marketplace enforcement. These potential changes could have a big impact on the 30+ states that have label approval laws as well as suppliers, wholesalers, retailers, and vendors. Many states would need to revise their statutes, change their regulations, and/or revisit their policies and processes if the changes move forward.
We’re going to hold a follow-up “part 2” to the COLA panel at the NCSLA Regional Conference in Atlantic City on October 12th. I’ll also touch on these issues during the regulatory roundup section at our annual Direct Sales Virtual Seminar on October 17th.
We want to hear from you! If you have any feedback, comments, or questions, please email them to COLApanel@shipcompliant.com . If you are a state administrator, and you haven’t yet completed our label registration survey, please do so in advance of the panel on October 12th by clicking here. Our goal is to have an open, collaborative discussion on this important topic and would love to have as much input as possible.