There was some interesting news yesterday, on BevLog. According to the site’s report, the TTB has announced that they are cutting back on some of the stringent review procedures that make submitting COLAs a hassle.
The TTB will no longer look at formatting requirements, expecting submitters the know the rules before submission. This means that the TTB will, theoretically, no longer sit on your label submission for a matter of months, just to return it because your color contrast was off.
According to Industry Circular 2011-04 (graciously uploaded by the good folks at BevLog), the TTB “will no longer examine labels to determine whether the images included in the applications meet the type size, characters per inch, and contrasting background requirements.” If you read further, the TTB explains that it reserves the right to review and return applications for these reasons when it deems necessary. Thus, beverage producers are not 100% clear of these requirements.
So, what does this mean? Well, my first feeling was that this might actually have a worse impact on COLA submitters. There is some potential here for the TTB to call for an adjustment to labels well after you have packaged your product and sent it off into the marketplace. That is a frightening thought, but its a reality in light of the new procedure.
My suggestion: know the formatting rules and setup internal controls. Ensuring that you are complying with the formatting requirements will save you a significant headache, down the road.