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?
Wineries beware! TTB label approval times are now back up to over 30 days!
Here is my post from 2 years ago w/info on how you can plan ahead for this necessary step in the process:
All wines that are bottled by wineries to be sold for consumption are required to have a federal label approval. The industry term for this is certificate of label approval, or COLA. Of the three alcoholic beverage categories (Beer, Wine and spirits) the number of applications for label approval received by the federal regulating agency, the TTB from the wine industry makes up over 80% of the total. Add to this scenario the current government budget issues which have resulted in staff cuts and retirements at the TTB and the end result is label approval processing time has gone up. Many in the industry had become accustomed to their label approval turn around time lasting about 10 working days. (This is for those using the TTB’s electronic filing system, COLAs Online) That time frame now has now gone up to 38 Days!
5 gallon kegs have become a popular way for wineries to get their product out into the marketplace, specifically the by-the-glass marketplace. I had a client contact me recently for assistance with a new label approval (COLA) for his upcoming bottling. I’ve filed these for him in the past but this year was the first time he’d decided to try out the 5 gallon keg route. He asked me if a label approval was required for them, and I honestly didn’t have an answer for him right away.
Here we are at years end. A time often focused on assessing the years events & developments, ups and downs. For the winemaking world 2012 has already been marked as an incredible one in relation specifically to the grape harvest. (At least here in California) But what about in relation to compliance? What were the stories there? And what’s to come for wineries in 2013 that they’ll want to pay attention to for keeping on top of their compliance?
Quick question my winemaking compliance friends, When you researched for the answer to a compliance question were you ever frustrated with the first answer you were given? And by frustrated I mean the answer you were given either was not very clear or just didn’t sound like the right one you were after? My simple solution when this happens to you? Get a second opinion.
Yes I know, “thankful” and “compliance” don’t usually show up in the same sentence together. But if you’re someone who has spent the past 15 years interacting with the TTB from a recordkeeping and reporting standpoint you can appreciate the improvements that have come along to simplify the process. Plus I’m a person who believes in a regular practice of gratitude. So in the spirit of this annual American tradition from our founding days I’ve summarized a few of this years compliance “developments” that I’m grateful for.
There are currently over 7,000 wineries in the US. I continually am in contact with folks at the beginning stage of starting a wine business, and many of those are as a “bonded winery”. Basically what that expression means is they are licensed as a winery, so a business that makes wine, grape to bottle. It’s a pretty exciting stage to become officially licensed, but then after that initial excitement wears off comes all the “what do I do now?” questions as far as compliance related to that new permit. Believe it or not everyone I interact with that is starting a winery is doing so because they’re excited about making and selling wine……….not because it means they’ll get to deal with compliance.
I recently wrote a post about one of the potential compliance side effects related to this years high yield harvest. Afterwards, while I was talking to a client I was reminded of another potential compliance issue. He asked about the topic of bond coverage and what happens if wineries go outside their limits.
First, let me put all of that into laymans terms and how it ties into this years high volume harvest. All wineries have specific bond coverage (TTB requirement) which is an insurance policy that covers the total tax liability for wines they have on their site at any given time. If their total volume goes over that coverage amount in the event of an accident or an audit they would be outside their coverage amounts on their TTB reports. In both cases something they can be fined for or worse, held responsible for tax liability on wine that accidentally was lost.
Winemakers, do you cringe at the thought of having to deal with your compliance? If you said yes (And you know all of you did) then I’ve got some good news for you. There are some simple ways to make keeping up with your compliance an easier task. Really, there are.
I’ve conveniently summarized a list of my Top 3 Tips just for you, which if followed consistently are guaranteed to spare you from a lot of unnecessary cringing.
Harvest of 2012 has definitely shaped up to be a very welcome banner year for wineries here in California. I’ve been reading story after story about the high tonnage amounts, and picture perfect looking fruit that has been arriving at wineries over the past two months. But what happens when too much of a good thing is showing up at your winery? That is you’ve got more fruit ready to come in than you’ve currently got tank space open to ferment it in?