Issue link: http://winesandvines.uberflip.com/i/131907
C O M P L IAN C E the producer decided to do the opposite on the label for the next year's bottling, then a new label approval would not be required. ABC Winery ABC Winery Red Wine 2012 Red Wine 13.5% Alc. by Vol. 13.5% Alc. by Vol. Left: Example of previously approved label. Right: New label with allowable vintage change. Steps to follow to assess whether or not a new COLA is necessary In the event that you are coming up on bottling a wine that your winery bottles each year, here is a series of steps to follow to determine whether or not a new label approval needs to be submitted. Step one: Locate your new label image files (full set of front and back) and the most recent COLA for that wine. Step two: View each set of labels side by side to determine the changes between the COLA already on file and your new label files. Make a list of each of the changes. Follow this step for each label individually, comparing the previous front label to the current front version and do the same for the back label. Step three: Compare each item on your list of changes to the TTB's updated list of allowable revisions to determine whether or not you will need to submit a new label approval. bcg is a provider of compliance and legal services to Federal alcohol and tobacco permittees. bcg provides consulting support on matters involving beer, wine, spirits, fuel ethanol, tobacco, TTB Tax Audits, and on other TTB compliance matters. bcg also provides general legal services to help you navigate complex legal and regulatory compliance matters. We are here to help you do what's right! For more information, visit www.bucklesconsulting.com or info@bucklesconsulting.com Market Research for Wineries and Suppliers WinesVinesDATA W W W. W I N E S A N D V I N E S . C O M 64 p r acti c al w i ne ry & v i ne yard J U NE 20 13 Impacts related to state-to-state shipping The TTB is not the only government agency that requires label approvals as part of its regulatory activities. At the state level, many wineries that ship to consumers or distributors in other states are also required to submit some form of label registration, and part of that label registration requires a copy of the federal label approval for that wine. I wondered whether any of the state agencies would have a conflict with these newest updates from the TTB in relation to their own state requirements. To verify whether or not this was the case I contacted Sarah Werner, manager of research at ShipCompliant in Boulder, Colo. Werner notes that wineries that have determined their label changes fall within the range of the TTB's most recently updated list should not need to get further COLA approval in order to register their new labels with the states. "The majority of states that previously required new or revised registrations for new vintages, wine class changes, alcohol by volume changes, etc., continue to require those registrations. We are not aware of any states at this time that have indicated they require wineries to apply for additional federal label approvals that would otherwise not have been required by the TTB." Summary One final item worth mentioning on this topic is that as far as qualifying for the use of each of these label items, that comes under the closest scrutiny in the event of an on-site TTB audit. If you list an alcohol content of 13.5%, "produced and bottled by" and a vintage of 2012 on your wine label, you would be required to show documentation in your winemaking records that clearly indicates the wine meets the minimum percentage requirements or other regulated qualifications for using those regulated items. To see a complete summary of the TTB's list of allowable revisions, visit ttb.gov/labeling/allowable_revisions. shtml. PWV Ann Reynolds is a wine compliance educator, author and speaker with 20 years of experience in the wine industry. She offers classes in many areas of wine compliance at Napa Valley College, Sonoma State University and UC Davis Extension. Her business provides wineries with on-site trainings and system development. She can be contacted at ann@ winecompliancealliance.com.