COLA - queue time placeholder image

[rtshfd]

We're currently redesigning the label for one of our products. It has an approved COLA, but we would like to change the fluff text and rework the graphics/design (from 2 labels to 1, adding a bit and taking away a bit).

I'm pretty certain I need a new COLA for the new label. We don't have a finalized version yet. My question is: can I submit with what we have currently and then swap out for a final version later? I want to get the queue time moving but I also don't want to waste that time if the approval comes back rejected because of a placeholder image.

Thanks for any insight

[Distiller76]

Yes, You can.

Right now COLA's are running about 26 days, so you'll get a jump on the wait. When you have the final version, Just apply for an amendment.

I'm not sure exactly what you're adding or taking away, But it may be an allowable revision not requiring a new COLA at all.

http://www.ttb.gov/labeling/allowable_revisions.shtml

[rtshfd]

Thanks for the response.

We're adding non-holiday related graphics, drastically changing the logo and changing the copy to something completely new. From what I'm seeing those all require a new COLA unless I'm misunderstanding.

Quick question, can an amendment be done through the colas online UI?

[Distiller76]

I think you should be able to, Yes

Dealing with TTB can be a serious pain sometimes. There are a pile of loops and hoops, And sometimes things that make perfect sense to me, will get flagged.

Just because I always want to be 100% compliant, And am obviously not a lawyer, I have a lawyer do all of my formula and COLA submissions.

The Lehrman Bev Law firm are great guy's to work with. I deal with John Messinger. Absolutely worth every penny.

http://www.bevlaw.com/

jdmessinger@bevlaw.com