The federal Trade and Tax Bureau (TTB) recently announced that it will enable a new “Conditionally Approved” status for Certifications of Label Approval (COLA) that will enable a simplified process for suppliers to correct applications with typos, a move that should bring welcome relief to all US beverage alcohol suppliers.
Previously, any error in a submission would prompt a “needs correction” response from the TTB that would require the applicant to correct and resubmit their application; this could add additional weeks to the time-sensitive go-to-market process. The TTB sent about half of COLA submissions back for corrections, often enough due to simple errors such as typos on application forms.
COLA changes should speed time to market
Starting on June 27, 2019, the TTB will let producers amend some fields in their COLA applications without having to restart the application process. When a TTB specialist notices an error in certain fields of the application, they will flag these errors and propose a correction that the applicant can either accept or reject.
A “Conditionally Approved” status is only available when a specialist proposes a correction to the following fields: Brand Name, Fanciful Name, Appellation (Wine Only), and Grape Varietal (Wine Only). These fields are particularly prone to typos in an application, and as the specialist can compare what is printed on the product label against what is on the application, they are able to recommend a proposed correction.
Once the applicant receives notice of their “Conditionally Approved” status, they will have 7 days to review and either accept or reject the proposed change. If the applicant accepts the proposed change, the status of the COLA will automatically change to “Approved,” and no further action will be required. If the applicant declines the proposed changes, then the COLA status will automatically change to “Needs Correction” and the applicant will be able to correct any errors themselves through the established correction process. If no action is taken within 7 days, then it the COLA status will move to “Needs Correction,” again following the established process.
In addition to the new “Conditionally Approved” status, the TTB announced other improvements to the COLAs Online tool, which will enable users to better track and manage their approved and pending COLAs.
For smaller producers in particular, the TTB’s move should be good news. The COLA process has improved by leaps and bounds in the last few years — many can remember the bad old days when COLA approval was expected to take well over a month. Currently, the TTB indicates that the processing time is expected in about 18-20 days, depending on the product type. However, there is still room for further improvement, and the new policy should dramatically reduce this time by eliminating a slew of time-consuming corrections.