TTB Label Approvals……Make Sure to Plan Ahead!
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!
What does this mean for wineries? They now need to re-adjust their planning schedules when coming up on bottling time. They now need to factor in a weeks longer time frame for label approval coming back BEFORE they are on their printer’s schedule to have the labels printed. The classic label printing scenario I have both seen and heard about many times is that labels are designed and printed BEFORE a label approval application has been submitted for them! Not good planning! Why not? Because in some cases the label approval came back denied which meant the winery had to have the labels reprinted and eat the expense of the first batch.
A best practice suggestion for wineries coming up on their bottling season now would be to follow these steps:
1. 3 months out from the bottling date the label design and details should be decided.
2. Once this is finished the completed label proofs are given to the person responsible for submitting the label approval applications. They look them over for all required items and details and submit.
3. In 2 to 6 weeks time the approval (hopefully) comes back.
4. The go ahead can be given to the printer to process.
I realize after my years working in the industry that this post may be a very entertaining one especially for those actually responsible for filing label approvals. It is still all too common that planning ahead for this part of the winemaking process does not take place like it should. That is, label approval is often almost an after thought in the label design and printing process. It is only a matter of getting into the habit of planning for it though and once that is the case wineries stand to benefit financially and in their staff’s morale. (No more stressing them out by printing labels before label approval!) I also highly recommend using the TTB’s COLAs online system for submitting label approvals even though the turn around time has slowed down from its earlier days it still is much faster than filing on paper AND it has a higher “success” rate due to the fact that there is somewhat less room for error. For more information on COLAs online here is the TTB’s link: