Posts Tagged: COLA

Government Shutdown Impacts Breweries

Planning to brew something that needs a formula approval or a COLA approval? Have a new facility in the works? If so, you might want to reconfigure your schedule because the government shutdown has caused the TTB to suspend many of its functions.  While you can still access certain functions on the TTB’s website, including Permits Online, Formulas Online, and COLAs Online, those applications will not be reviewed until after the government shutdown is over.  In addition, TTB personnel have been told not to report to work and, according to the website, are prohibited by federal law from volunteering their services during the shutdown.  This means that if you have a question or an issue with your application, nobody at TTB is available to assist you. Furthermore, TTB cannot update its website during the shutdown, so it is possible that some of the information will be outdated or otherwise inaccurate. We still recommend that you file the applications because there is no telling how long or short the shutdown will be.  Moreover, if others file and you do not, there could be a significant backlog once regular service is restored, which could further delay approval of your application. (more…)

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TTB Expands Allowable Changes to Labels without Resubmission, but Reminds us that One Label “Does Not (Necessarily) Fit All”

Certificate of Label Approval (or COLA) can be one of the more frustrating processes for brewers.  Each label must be approved by the Alcohol and Tobacco Tax and Trade Bureau (TTB).  Once the COLA is issued, only certain, limited changes can be made to the label without resubmitting it for new approval.  In many situations, there are state requirements that must also be met.

Until March 26, 2018, there were only 34 categories of label revisions that could be made without a new application.  On March 26, 2018, the TTB issued Industry Circular Number 2018-2, which amended an existing category and added three new categories of label revisions that may be made without submitting a new application (click here for the full list of categories). (more…)

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No New COLA Required to Add Brewers Association’s Independent Craft Brewer Seal to Labels

The Brewers Association continues to streamline the process for eligible brewers to adopt the new independent craft brewers seal. Obtaining a license to use the new seal is relatively straightforward and only requires (1) a valid Tax and Trade Bureau (TTB) Brewer’s Notice, (2) confirmation that your brewery falls within the Brewers Association’s “craft brewer” definition, and (3) agreement to and compliance with certain licensing terms. More information about the new independent craft brewer seal can be found in our previous blog post, “In the Beer Aisle: Independent Craft Brewers to Stand Out from the Rest of the Pack(s).” (more…)

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