The TTB continues to tweak their various online filing websites. Their COLAs Online website, which is used for submitting label approvals for all alcoholic beverages has recently made changes to the varietal field. For an office like mine that regularly files a lot of TTB label approvals I’m usually pleased to see the improvements they continue to make. Most recently though their last change actually messed up a couple of applications I had in at their “review” stage. They were messed up in that they (almost) lost the varietal that had been entered in that field. Each of these applications came back to me “needing correction” as the TTB puts it. When I opened up each application to respond to the edits they requested when I got back to the final review screen to re-submit them I noticed that the varietal field was blank. I went back into that area of the application and there now for the varietal field is a drop down list of all currently approved varietal names. I selected the correct varietal name for each of my applications and resubmitted both. (which quickly came back approved) If I had not caught that blank varietal field hiccup the COLA would have come back with no varietal listed.
This is a potential issue on an audit level, meaning that if a wine lists a varietal name on its label, but the label approval (COLA) for it does not the TTB could take issue with this if they were to audit that wine label/wine blend. So for all who are reading this that regularly (or irregularly) submit TTB label approvals keep an eye out if any come back to you “needing correction”. Make sure to double check if you listed a varietal to select it again from the drop down list now in the varietal box before you resubmit that application.
On the plus side of this improvement is the fact that you can’t submit a label that lists a varietal name that is currently not on the approved list. There are currently a few hundred approved grape varietal names on that list. Plus an additional group that are pending approval. My guess is that the TTB label approval staff were regularly seeing varietal names listed on applications that are currently not on that approved list, which turn out to be a waste of everyone’s time. (& money potentially for the winery)
But what about if you have a wine label that lists several varietals along with their percentages? This is an allowed label option for wineries and has become somewhat common. If that is the case for a label then the submitter will just need to select all the varietals listed one by one from the drop down list.