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Video: Who is ALWAYS responsible for obtaining a TTB label approval?

TTB label approvals, or COLAs as they are referred to in the wine world. A topic that I hear no shortage of questions around. Not at all surprising really since there is a lot going on around a wine label and the TTB label approval that is required to be submitted for it. (*In most but not all cases)

One FAQ about TTB label approval that confuses many in the wine industry is about who is the responsible party for obtaining one before a wine is bottled. This question is specific to a very common scenario in the wine world, which is when wine that is owned by one winery or wine business will be trucked to another winery or wine cellar site to be bottled. Who is the responsible party in this type of scenario? 

Plain and simple, it is always, always, always the site that physically bottles the wine that is the responsible party for obtaining the label approval for that wine. Let me add to that for all  sites out there that have "many wineries" at your site because those "many wineries" are alternating proprietors (APs) the responsibility falls on whichever TTB permit the wine is bottled under.

Watch my video here: