Guess what Alternating Proprietors? You CAN take your COLAs with you!
Posted on 2013-06-05 by Ann Reynolds

Today’s blog post is for anyone who either is an Alternating Proprietor (AP) or is a site that hosts them & offers TTB label approval submission assistance. I just learned this newest TTB update twist last week that can save you some time when planning for your bottlings- by eliminating the need for the label approval step in that process. Here’s the scenario I’m talking about. One of the advantages as an AP is that since you are sharing the space of an already existing winery if you decide you need a change of scenery you can pick up and “move your winery” to another site that hosts AP’s. Now after you’ve made that move, how does it then impact your label approval activities?

After you’ve relocated your AP to a new site and are planning to bottle some wine you may qualify to use one of your existing COLAs from wines previously bottled at your original AP location. (So in other words no need to submit a new label approval) Basically here are the steps to qualify for this:

(1) The new winery site you move your AP to must still be in the same state

(2) The label for the wine you are about to bottle must only have allowed changes to it. Here is a link to that list:

 http://www.ttb.gov/labeling/allowable_revisions.shtml

To give you an idea what this entire scenario might look like say you’ve recently relocatd your AP that was hosted at a winery in Napa to another winery also located in Napa. (FYI,yYou don’t have to still be in the same city, just the same state) You are now planning to bottle the next vintage of a wine you produce each year. Take a look at the label you plan to put on that wine and compare it side by side to your already existing label approval from the last bottling. Look for any changes between the two. Take note of what those changes are and then see if any of them show up on that updated list from the TTB.

Chances are you may be fine & not need to take the time to file for a new label approval, which these days can save you over a month’s worth! (see the most recent info from the TTB on their label approval turnaround times: http://www.ttb.gov/labeling/labeling-resources.shtml

The TTB has already received closer to 70,000 label approval applications so far this year. They’d really like to shrink that number, and their most recent updates in allowable changes is a good one to be familiar with to help them do just that AND save both them & you some time in the process.