COLA Craziness

[rumfarmer]

I have two approved labels for my agricole rum. One for a white version called KEA and one for a barrel aged expression called KOHO. Both labels are essentially the same other than the names KEA and KOHO, and the fact the they have different tamper seals where one uses copper leaf and the other silver. Now, I have put in for a new product that will be a cask strength version of the KOHO. This label is all but identical to the KOHO label, but the new product is called KOA and we use a red leaf instead of copper (also higher proof). TTB came back and rejected the KOA label for reasons already approved on the other two labels. So, what is the best course of action? Do I point out that they already approved my other two labels? Does this open a can of worms on the already approved and in production labels?

Any advice much appreciated.

[Artisan Still Design]

resubmit it with no changes, you might catch someone different, or the same guy in a better mood.

[fermental]

Did they provide a reference to the part of the code that they based the rejection on?

If so I'd update what they requested, because it may be that the original analyst missed the exception on the two other labels - and they may request that you change the two that were previously rejected at some time in the future.

[rumfarmer]

That is my worry about the other labels, but it is nuts that I could have two submissions of two labels at different times where both analysts missed the same thing, then the third guy says no to it:

RUM must appear separate and apart (on a separate line) from any other descriptive or explanatory information per 27 CFR 5.33((2).

[daveflintstone]

Call the person who rejected. Don't bring up your other approved labels. Point out the obvious major brands with words in addition to "rum" on a line, like Captain Morgan (spiced rum), Appleton Estate (Jamaican rum), Sailor Jerry (navy rum), etc. etc. etc.

Logic doesn't always prevail but the sheer dominance of labels like this is persuasive.

[rumfarmer]

Thanks Dave.

[Sorghumrunner]

COLA craziness it is. I've been fighting to get Amber on the same line as Rum, TTB will not allow it despite several requests and showing them 4 other labels with the same. I've got bottles from other distillers with Alambic Rum on the same line together, and they've asked me to remove the word Alambic from a descriptor that says 'Alambic distilled'.

People say they let things through, but I seem to get called on any possible issue that I've submitted. I spoke with a Liquor Lawyer, who offered his services for some $$$, but even the letter he did write for me on the subject to TTB did nothing to help with the Amber Rum issue.