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COLA - what to expect


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We have a COLA application ford our label submitted as of May 5. Looks like review times are hovering between 19 and 22 days for spirits. 

I'm scratching my head about what the processing times mean. The description reads that it is the number of days from when the application was received until it is rejected or approved and includes time spent going back and forth with corrections. Is that still the case? 

Further, if TTB rejects a label application and you choose to correct it, does your application go to the bottom of the pile again?

thanks for any insights into how this process unfolds. We are itching to get going, but are stuck waiting on labels (of all things). 

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I think that time is how long it takes to get to the top of the stack and get reviewed. Once it's at the top and gets rejected your corrected submission goes back to the top.  So it's usually a day or so to get a rereview, not another 20 days. 

If you need help call them. I had a formula that was causing issues on the label. One I got ahold of a specialist they were able to update the formula quickly so the label could be approved.   

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After submitting a COLA it will take that many days to get a kick back where they either ask for amendments or they approve.  If you have something glaringly wrong I find that the second it hits the hand of the reviewer it gets kicked back (no origin statement, no gov't warning, something like that.)  That first kickback is usually shorter than what it takes to do a final approval.  

In terms of resubmitting, you have a period of time (a week?  10 days?) to fix the problem and resubmit your app.  It will then be at the top of the figurative pile and be approved within a few days.  

You can start production, just can't remove from bond without an approved label, obviously.  If you're waiting on a cola, you can fiddle with that process while producing the product for the bottles.  Start the bottling process and label after, or wait till the labels come in to start the labeling/bottling.  

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It took over 3 months from submitting our first COLA to hear anything back. Once it was rejected we made corrections and had the approval within 2 weeks. Submitting during the holiday season could be the reason it was held up. I hope it does not take as long in the future.

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  • 8 months later...

Sometimes it can go fast. I just submitted one yesterday that was approved in 24 hours! But there were extenuating circumstances: this was a modified version of another label approved a month ago, where all we changed was the primary graphic and minor text. It was not a correction–it was a new submission. But in our comments, we pointed this out, including reference to the prior COLA. I suspect that was the cause of the speedy result, but it is something to keep in mind: make their job easier if you can.

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