12 replies to this topic

[Paul G]

Have any of you encountered any nightmarish tales of COLA approval?  I recall St. George was delayed longer by their label than their formula.  Anybody else run into similar situations?

[Spirits Review]

Paul G, on Jul 30 2008, 06:15 PM, said:

Have any of you encountered any nightmarish tales of COLA approval?  I recall St. George was delayed longer by their label than their formula.  Anybody else run into similar situations?

According to almost everyone involved with Absinthe (distillers,importers, etc., )that I have talked to (we do a lot of Absinthe reviews) they were  all about ready to tear their hair out- seems the average is at least 5 tries.

[grehorst]

So far we've had annoyances- not quite horror stories. Of course there's always a first.

Our biggest problem stems from the fact that (most of) our labels are printed on clear label stock. The application examiner needs to verify that the contrast of legal text is going to be adequate, and they frequently have trouble judging that from the artwork files. In the case of our Gin they requested a photo of the label on the bottle to prove the contrast was adequate. Of course that meant I had to get the labels printed first! So, knowing that their only concern with that particular label was the contrast and knowing that the contrast was excellent, we bit the bullet and had 10,000 labels printed. Fortunately when they saw a photo of the bottle they were satisfied with the contrast.

[Paul G]

Despite being after-the-fact, would it work (for potential future labels) to laser print on a transparency for a one-off prototype?

[grehorst]

Paul G, on Jul 30 2008, 08:32 PM, said:

Despite being after-the-fact, would it work (for potential future labels) to laser print on a transparency for a one-off prototype?

Not in this case- our gin label uses a bunch of white ink. You can't print white ink with a laser printer. I guess we could have replaced white with another color but I didn't relish the idea of explaining to the label reviewer that the color I printed, while not white represents white.

[Paul G]

White out?  

Lots of valuable details to file away for reference, thank you!

[grehorst]

Paul G, on Jul 31 2008, 12:07 AM, said:

White out?

Lots of valuable details to file away for reference, thank you!

Actually I thought about printing on clear, and then using a white sheet of paper to simulate the white, but of course we had to complicate it even more- the white on the bottle is a gradient.

[Donald R Outterson]

Beer Schnapps as a label has not been approved by the TTB for 4 months 3 tries and counting, the formula from the local microbrewery was accepted on the 2nd time through.  Its been over 2 years so far and it is fighting me every step of the way.

We are now re-submitting to product with a faciful name and not calling the product beer schnapps at all.

Any suggestions?

I have one for us all! Tax payer Advocate Service (TAS) is for problem cases not resolved though normal channels.  It is used in other areas of the Dep of Treasury such as the IRS with great success, but not at the TTB. I have repeatedly suggeted to the TTB that this service be implemented in this area of the Treasury as well.  So, far they have not responded.  Perhape ADI should document a industry request for TAS to show the need in the full light of day. The would allow our special needs to be addressed and would provice our industry with an advocate that answers directly to congress rather than the TTB.  They will then be required  to respond on time and will be documented on their actions for all too see.  Why not be included with the rest of the businesses?



Donald R Outterson
Woodstone Creek

grehorst, on Aug 1 2008, 10:16 PM, said:

Actually I thought about printing on clear, and then using a white sheet of paper to simulate the white, but of course we had to complicate it even more- the white on the bottle is a gradient.

[Paul G]

What sort of issues has TTB had with Beer Schnaps?  It's something I was looking into making, too, so I'm curious to see what the ultimate work-around will be...or could be.

Have you yet tried the German spelling "Bierschnaps" yet?  It appears that Essential Spirits in northern CA has gotten by with it.  Theirs.

Quote

I have one for us all! Tax payer Advocate Service (TAS) is for problem cases not resolved though normal channels. It is used in other areas of the Dep of Treasury such as the IRS with great success, but not at the TTB. I have repeatedly suggeted to the TTB that this service be implemented in this area of the Treasury as well. So, far they have not responded. Perhape ADI should document a industry request for TAS to show the need in the full light of day. The would allow our special needs to be addressed and would provice our industry with an advocate that answers directly to congress rather than the TTB. They will then be required to respond on time and will be documented on their actions for all too see. Why not be included with the rest of the businesses.

That would make sense.  I have a gut feeling that TTB is woefully behind in manpower to keep up with the needs of the industry it governs...in typical government fashion.  It's obvious that as the microbrewing/distilling continues to grow, TTB will have a greater volume of work to  handle.  I just hope they recognize this before it drives potential businesses under by not having product to move due to application.

Then again, change in the government is like elephant sex.  Everything happens high up, there's lots of screaming, and you have to wait two years to see the results.

Keep us posted on the "Biershnaps" (maybe?) and let us know what finally flies.  I'm hoping to follow your lead  

[grehorst]

Donald R Outterson, on Aug 3 2008, 11:07 AM, said:

Beer Schnapps as a label has not been approved by the TTB for 4 months 3 tries and counting, the formula from the local microbrewery was accepted on the 2nd time through. Its been over 2 years so far and it is fighting me every step of the way.

We are now re-submitting to product with a faciful name and not calling the product beer schnapps at all.

Don, we just got our Bierschnaps formula approved. I need to get my label approved in the next 30 days to bottle for "pumpkin" season. If we miss that, not much point in selling the product this year... now you're making me nervous- what reasons have they given for label rejection?

[Gwydion Stone]

I finally received my COLA for Marteau Absinthe a few weeks ago after starting the whole process last October.  Nine months.

The formula was submitted in October and approved in January.  The label was (first) submitted in January and approved in July.  The delays were the biggest problem; we only had three rejections, all for minor grammatical issues because absinthe doesn't have a designation as a class yet.  I had originally wanted to say in the incidental language that Marteau was a "refreshing herbal aperitif spirit", because that's what proper absinthe is.

Note: Apparently beer and wine can be "refreshing" but spirits cannot.  Then it becomes a claim of therapeutic value.  A wine can be an "aperitif" but, centuries of history notwithstanding, a spirit cannot.

Based on this experience, I would also recommend that everyone use COLAs Online and get to know your specialist.  We went through a consultant on this one and paid for nine months of headaches, frustration and mounting debt.  DIY is better; but we all know that, don't we?

Discussion thread and pics at the Wormwood Society.

[Andrew]

Congratulations! I've been looking forward to the product.

Has there been any traction on defining the class/type for absinthe?

[Gwydion Stone]

None I'm aware of.  I've been fine-tuning a petition for over a year and I think it will be ready before long.  These things must be done delicately, and there are still areas of controversy even among the most knowledgeable absinthe historians/makers/aficionados.

My feeling is that the new class should be as broad as is necessary to allow for growth and cautious, well-informed innovation, while still being firmly rooted in the historic identity of the category.  Others take a more conservative approach and tend to want to enforce the ideals of pre-ban quality as if they were the standards of identity.

My biggest concern is the ridiculous notion of "anise-free absinthe." Imagine anise-free ouzo. Once this idea takes hold and the general public is convinced that such a thing is possible, it will mean the destruction of absinthe.  Ironic that "lifting the ban" would be the thing that finally killed it.  

But we can take this up in the absinthe threads, rather than derail this one.  Sorry.