New Label Rejection... any clues?

[Classick]

So i have a label in for approval, and they just rejected it with something i have never seen in 14 years of distilling/getting labels approved.

The Application needs correction for the reasons listed below. Click on the "Make Corrections" link above to edit the information from your original submission. All corrections must be completed by 04/12/2012 or the application will be automatically rejected.

Reason Additional Information The company name or the trade name on the label is not listed on your permit. 27 CFR § 13.21 Your trade name or “DBA” must first be updated with the National Revenue Center (NRC) which administers permit records. You may update permit records either in writing, via e-mail at ttbwine@ttb.treas.gov, or via Permits Online. Your COLAs Online user profile may then be updated to reflect this information. [The trade, Muscardini Cellars, is not a trade name of record, as indicated on your label, attachment document, and application.])

We have completed in dont know how many DBA's in the past... and have never received this error. We had attached a scan of the approved DBA from our county along with the label submission.

Any thoughts?

[Beauport Bob]

Dave, years ago we did get a "trade name" rejection once, I believe. We had neglected to put the comma in our name: Ryan & Wood, Inc. It was considered a "D.B.A." without the comma in place. This may have been a result of auto scan rather than "eyes on" . It was an easy fix.

[Kristian]

I spoke with our specialist at the permit department about this. You have to send in a letter on the DBA letterhead stating your distillery has permission to use the DBA and an application to ammend basic permit http://www.ttb.gov/forms/f510018.pdf fill in section 6 and email it to your specialist.

I hope this helps.

[bluestar]

Right, if you actually are listing your DBA as distiller on the label, and that DBA is not on your permit, you have to amend the permit or change the label. They do not allow you to DBA without registering it with the TTB, not just your local or state. Doesn't mean it may not have gotten through before, but it is legally required. When you amend, they will want the documentation from local/state for DBA, as they would for initial filing.

[Classick]

I spoke with our specialist at the permit department about this. You have to send in a letter on the DBA letterhead stating your distillery has permission to use the DBA and an application to ammend basic permit http://www.ttb.gov/forms/f510018.pdf fill in section 6 and email it to your specialist.

I hope this helps.

Thanks Kristian. We did include a scan of the official DBA information along with the label approval as we have in every previous submission.

I think what happened is in Step #2 when submitting the application, I might have forgotten to select from the drop down our DSP#. Thus, the submission would not be linked to our DSP permit. I have resubmitted the application, today and am hoping that that small change was the issue.

Thanks for the suggestions folks. Hopefully if this is resolved, this thread will serve as a clue if this happens to anyone else.

Have to remember to dot the I's and cross the T's

[Classick]

so apparently they kicked it back again, and now are requiring us to provide a list of all previous DBA's... god damn TTB.

We have done i dont know how many DBAs in the past, exactly as we have this one.. and never had any issue with it. and now all of a sudden we are required to register every single one? This is lunacy

[bluestar]

Sorry, Dave, to hear you seem to be caught in the classic (Classick?) "data mining" situation typical of regulatory agencies when they learn enough to suspect that not all required information has been submitted in the past. In this case, if you have had changes of DBA that were not filed as permit amendments (which is required), then they may want to update the complete history. Sounds like they may have let you slip through in the past, and now they are trying to retroactively obtain all the required information. Did you speak with your assigned specialist to make sure you are both on the same page before making another submission? Let us know how it is resolved and why, so we can all benefit from any lessons learned.