Difficulty with COLA Label Approval

[Sator Square Distillery]

I'm wondering if anyone has any advice on how to speak to a human being at the TTB COLA Distilled Spirits label department. I submitted a label about a month ago for a Marc Brandy. Since it's flavored, I had to first submit a formula. In my formula I describe the end product as a pomace brandy, as I  have made it with 100% wine grape pomace. On my label I wanted it to be identified as a Marc Brandy.

I figured this is no problem because in Chapter 4, on page 4-7 of the TTB's class and type designation manual, it reads:

POMACE BRANDY OR
MARC BRANDY

“Pomace Brandy” or “Marc
Brandy” is grape pomace or
marc brandy. Other types of
pomace or marc brandy must
be further identified, e.g.,
“Apple Pomace Brandy,”
“Pear Marc Brandy”

Clearly, by the TTB's definition pomace brandy and Marc brandy are interchangeable terms. Either of these terms applies to my brandy. My TTB specialist has sent it back to me twice asking me to have my label redone as a pomace brandy. I cannot reach anyone at the TTB as no one answers the phone there. I have left numerous messages and no one has called me back, and I've sent emails asking for help clarifying my label.

Does anyone know of any way to reach a person there?

 

[Tom Lenerz]

Since it’s flavored you are probably DSS, so you’d have to go with something like Marc Brandy with X Flavor. 

[bluefish_dist]

We had a similar issue with a formula that I submitted slightly incorrectly.  I eventually go ahold of a specialist, but I don't honestly remember how I did it.    I know I called in and eventually got someone.  

[Sator Square Distillery]

My label as submitted reads Marc Brandy with XXX flavor. The problem seems to be that on my formula I used the word "pomace". I did that because yes, I fermented grape pomace and then distilled said pomace wine into a Marc/Pomace Brandy. The specialist doesn't seem to understand that "Marc" and "Pomace" is interchangeable.

Very annoying.

I think I'm just going to submit a second formula that only has the word Marc in it and then resubmit the same label. It would be quicker then trying to get the specialist to read their own manual I guess.