3 Steps to Certificate of Label Approval – COLA
Step 1, The Submission
An applicant submits the label application with complete, legible copies of labels to the Alcohol and Tobacco Tax and Trade Bureau (TTB), via Certificate of Label Approval’s (COLA) online site, or in paper. According to the TTB, a “label” is any label affixed to the bottle. This can include front and back labels, neck labels, foils (capsules), emblems, etc. If the label is blown, embossed, or carved into the bottle, a full description must be noted on the application.
Lindsey A. Zahn, Esq. is an alcohol beverage and food attorney at Lehman Beverage Law, PLLC. Ms. Zahn has previously counseled wine, beer, and spirits companies on licensing and compliance, federal and state labeling, customs regulations, supplier agreements, and advertising and promotions. She is an award-winning author on wine law, publishes a leading wine law blog called On Reserve, and has traveled to over a dozen wine regions in the U.S. and Europe.
John D. Messinger, Esq. is an attorney at Lehrman Beverage Law, PLLC. He joined the firm in 2006 as a law clerk, after working as an intern and consultant with the World Bank, Legal Operations and Policy. John focuses on TTB labeling and formulation matters and also state compliance issues.
John has a particular interest in beer and craft beer issues, and he is an avid small-scale brewer.
In this CLE class clip, Lindsey and John discuss Certificate of Label Approval – COLA.
Step 2, The Review Process
In general, the TTB will review and process the label in 20 to 30 days. You can expect to see your application in one of four different statuses; received, assigned, in review, and hold for research.
If there are issues with the label, or the application, the TTB will issue a correction notice. If an applicant receives a correction notice, they have 30 days to respond, otherwise the application is rejected and they must start the process over again. During the 30 days, an applicant can revise the application or argue their side. Any applications resubmitted, will go to the front of the line.
The TTB can, and will, reject the application if repeatedly returned without the requested corrections.
Step 3, The Approval
Once an applicant is approved, labels never expire unless specifically qualified with an expiration date, which is not common practice. The applicant may access approval immediately. All approvals appear in TTB’s public COLA registry in approximately 48 hours. This information is public record, anyone can see your approvals.