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TTB COLA's being much more picky lately?


clearwaterbrewer

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I am getting every single COLA rejected multiple times for mostly 'imaginary' issues...  exact same label layouts approved for two years now saying that my alcohol content statement cannot be on wraparound portion of label (it is not, it is a 4" wide label on a typical 750ml, completely viewable from the front), and rejecting every fanciful name, asking what the fanciful name means...  Big G as a variant of our Gin...  If I have to explain what every fanciful name means other than fanciful, I think e these folks are trying to justify their jobs or more staff by just clicking through all 10 of my COLA's and hitting reject and typing in one sentence padding their COLA count...

 

others seeing this?

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Yep. They wanted us to remove "Pillage Responsibly" from the inside of our labels.  We fought them and argued that if Bud could use "Remove "no" from your vocabulary tonight #upforanything" then we could use something as harmless as "Pillage Responsibly".

 

 

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now my formulas are getting nit-picked...  

I had 3 species of vanilla 0-5%, and stated in the method of manufacture that at least one of them would be used, but gets kicked back for having zero values for ingredients.

I replaced then with generic ingredient 'vanilla bean' and then it gets kicked back for something else "There is an error in the following field::"  (no field listed) and they get a bit snooty:

Quote

3rd return-Please do not submit until corrections have been made or your submission will be rejected. Questions-send email to <name removed>@ttb.gov

I cannot find the error, I have a half dozen other formulas that 0-1% for a dozen botanicals or more that went through fine...

what is inherently wrong with having 0-0.1% as a quantity, giving you the choice of leaving a trace amount of something out of a product?

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Try giving them a call.  I had some issues with a formula and was completely perplexed over what they were asking, I called, left a message and to my surprise they called back.  After a 15 second conversation it was resolved and they approved the formula.

I think the problem is they have a handful of people who deal with thousands of formulas and labels each day.

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A brewer friend yesterday told me that "Battle" Martin (guy in the article Clear Water posted) retired recently and breweries are now having similar issues getting COLAs approved.  His understanding being that there is a now a new person(s) doing the approvals who is being more picky.  I do not know if this same guy also did the COLAs for spirits or just Beer as none of the articles I have read about him mention that.

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ahh, this just cam back a minute ago:

Reason Additional Information
As an attachment, please further explain/clarify the statement and/or graphics shown on the label.   What does the letter Q mean? If it has no meaning then you must state so in the notes to specialist.
Please do not resubmit this application until all of the required corrections have been made. Making only one correction or none of the required corrections, then resubmitting the application may result in your application being rejected. Keep in mind that you have 30 days to make corrections.  

 

I did, in fact, already put in the 'specialist notes' that the fanciful name "Half Mine - Q" was just a fanciful name  variant of the base Brand "Half Mine"

 

 

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I may have found an issue, I went from step 2 to step 3 in  and it removed my 'notes to specialist' :-(  ...  I tried both Chrome and IE with the same results, so I copied the text to a 'notes to specialist.txt' file and added via 'upload other attachments'...

crossing fingers...

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Just make sure you get the corrections done to the actual formula vs. reply to their comments - I didn't and they rejected and closed the application; I called and was told if the corrections aren't made in the document by the third communication, it automatically gets rejected and closed.  So, I had to resubmit and have now been 'in the que" for over a week.

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I started putting the below in my method of Manufacture:

 

Quote

I have gotten formulas sent back because ingredient values were zero, to alleviate any confusion, per the following document, on multiple pages, it states:

"Note: You may enter a Quantity (Low) value of 0 (Zero)"

https://www.ttb.gov/foia/fonl-docs/create_a_new_uniform_submisssion.pdf

 

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and now another label kicked back  saying to remove 'with other natural flavors" from the line below 'Pepper Flavored Vodka'...   

no mention of why I cannot put that in there....

It has already been kicked back once because 'vodka flavored with peppers and other natural flavors' was misleading....

 

I wonder how Crisco gets away with a picture of fried chicken or cherry pie on the label?

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