Federal Government Shutdown and COLAs

The current federal government shutdown has put a halt to TTB’s regular operations and that has had a ripple effect on the alcohol beverage industry.  Wine producers and importers must obtain a Certificate of Label Approval (COLA) for wines they sell in interstate commerce.  While the online system for submitting COLA applications is still operational, TTB is not reviewing or approving those submissions during the shutdown period.   This may result in a delay in the ability to introduce new wines in the market.

Thankfully, there are a number  of permissible label revisions that do not trigger a need for a new COLA.  For example, if you have a COLA for your 2017 rosé and the only change in the label for your 2018 rosé is the updated vintage date, you’re in luck:  no need for a new COLA.

We recommend that wineries and importers familiarize themselves with this list of allowable revisions.  So long as your planned label changes fall within one of those categories, the temporary pause in COLA application review will not affect your ability to bottle and release that wine.

For more information regarding federal labeling regulations and COLAs, please contact John Trinidad.