TexCF

Can't help you there, but if you're not already making any non-alcoholic products, remember to review your FDA registration and see if it needs updating.

Well, if you've never gotten a needs correction for something like "misleading" label content then it sounds like you don't need to worry about it.

Just now, TexCF said:

A lot of the regulations outside of mandatory label information don't apply to labels subject to an exemption from COLA.

It doesn't shorten the time it takes for a specialist to review it by the way, but it does decrease the likelihood of a need for correction.

A lot of the regulations outside of mandatory label information don't apply to labels subject to an exemption from COLA.

Here's some talk on it:

http://www.alcohol.law/digest/the-supreme-court-rules-in-tennessee-retailers-what-does-it-really-mean

I have a middling palate and I'd probably go 6-7/10 picking out straight malt whiskeys fermented and distilled on grain. To me, it imparts a grain-flour like flavor and bitterness that caries over into the distillate. I don't like it. Some people don't seem to mind.

6 minutes ago, TexCF said:

You write a brief explanation on Schedule B of your excise tax return form (5000.24), along with the amount of tax you're claiming a credit on.

Wait a second, I thought you meant after you've destroyed them.

You cannot take back taxpaid spirits and return them to normal inventory. They cannot remain on the premises and must be physically separated from untaxpaid spirits. If you bring them back in, keep them segregated and ship them right back out. You're only supposed to return taxpaid spirits to your premises for one of the following activities: destruction, denaturation, redistillation, reconditioning, or rebottling.

2 minutes ago, bluestar said:

Okay, this raises a secondary question I could not get a good answer out of CFR or direct query to TTB: how do you get credit for taxes paid when product is returned to bond? Simple case: product sent to a distributor, tax paid, then product returned from distributor?

You write a brief explanation on Schedule B of your excise tax return form (5000.24), along with the amount of tax you're claiming a credit on.

My understanding is that the spirits must be returned to bond prior to destruction in order to claim a credit on the federal excise taxes. There are some companies who offer to bring it onto their bonded premises for destruction and pay you a portion of the credit, so you don't necessarily have to destroy it yourself. However, I do not believe you can claim a refund on federal excise taxes for product that was destroyed by the distributor. State tax issues may vary.

You did the Noble Rey labels, right? It's too bad about them, but that packaging was awesome.

You should post this over on reddit.com/r/firewater if you haven't already.

I've never worked with him personally, but Lehrman and his team handle a ton of COLAs. www.bevlaw.com

The way I see it, you have at least two options depending on when you submitted the original amendment.

If you submitted that amendment a while back, wait and then apply for the TIB (along with any other changes you may need to make that are priority).

If you don't want to wait and then apply for the TIB, do this: call the NRC, provide the amendment ID from PONL, the NRC rep will give you the name and contact info for whoever the amendment has been assigned to, e-mail that specialist with the ID number in the body of the e-mail and ask that it be withdrawn. The specialist then should (in pretty short order because it helps their clearance rate) withdraw your application for amendment on your behalf.

That's worked for me in the past.

Good luck and, if you don't mind, please update this thread with how long the amendment took to get processed.

This pasted directly from TTB's list of allowable label revisions:

"You may.... Change the.... proportionate size of labels" (emphasis added) "If you received approval for a single label then you may not divide the label into multiple labels without reapproval."