TTB is facing severe challenges as the number of industry members continues to grow at a rapid pace and the TTB resources available to process work items, specifically applications for label approval, shrinks. Since label approval is required before a product can be introduced into the marketplace, TTB delays related to label approval affect industry members ability to move new products into the commerce stream. After careful examination of the current procedures for processing label approvals, the current regulatory requirements, and data regarding label noncompliance, TTB has determined that marketplace enforcement of Federal alcohol labeling requirements would be a better use of the available resources. TTB is not considering eliminating the requirement to obtain a Certificate of Label Approval (or COLA), but is seriously evaluating a move towards a simplified approval process where the COLAs Online electronic system would issue automated decisions for certain eligible labels, based on information provided by the applicant. Simplified COLAs may not contain an image of the labels, which would impact the TTB Public COLA Registry. The most complex labels or those at the highest risk for non-compliance would remain subject to traditional label approval by TTB personnel. This change would allow TTB to shift resources to marketplace enforcement of the most egregiously non-compliant labels.
TTB understands that many states rely upon TTB-issued COLAs, and even though these changes are several years away from being implemented, it is important for states and industry to start thinking about how changes to the TTB label approval process might impact their operations. Please take some time to answer a few questions on these issues in advance of the upcoming NCSLA Conference panel: COLA CHANGES ON THE HORIZON
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