So last week’s post on the newest changes coming this month to the TTB’s online label approval platform COLAs online has caused some confusion with many readers. (Surprise!)
Sorry about that readers- I certainly don’t want to add any compliance confusion to your lives!
The updates the TTB is making this month to their COLAs online platform are to remove three fields from the application screen, which are alcohol content, vintage and net contents. So you’ll no longer have those three fields to fill in on the application.
However, here is the clarification on this change. While these fields are being removed from the application-
Alcohol content & net contents are always required items on a wine label!
Vintage is not a required item, but if listed must meet minimum percentage requirements of CFR 4.27
There will simply no longer be fields for these three items on the label approval form, be that online or on the paper form. (if you’re still living in that world)
So all you winery staff reading my first post or this one and scratching your heads no worries- the way that you’ve already been accustomed to interacting with the COLAs online platform won’t be changing too dramatically.
You’ll just no longer have to fill in an alcohol content, a vintage or a net contents field. *But your label will still be required to list at least two of those three items. For example, If you were to submit a label for approval that actually did NOT list an alcohol content it should come back to you “requiring correction” as the TTB puts it because alcohol content is a required wine label item.
The other change being made to the application is the appellation field, which has already been part of the application for years. Now you will also now have to fill in two drop down menus selecting first the type and then the name of the appellation(s) that is (are) listed on your label.
The TTB’s update has some screen shots of what this will look like for all who’d like a preview.
Here again is a link to the TTB update summary.