The TTB has decided to throw a bone to all of us who have to navigate through COLA submissions. It’s a very big bone.
For years, people have clamored for more freedom in the COLA submission process, and finally they are going to give it to us. The TTB commented that over 146,000 label submissions were submitted last year (10% raise) and that it has finally become too daunting a task to manually review each one. With resources becoming scarce there is one solution – limit the application requirement with more allowable revisions.
The TTB has implemented Form 5100.31, the newest version of the Application for Certification/Exemption of Label/Bottle Approval. The new form comes with an incredibly expansive list of Allowable Revisions, which is a term of art for those label changes that do not require resubmission to the TTB for approval. The list of Allowable Revisions (in a neatly crafted chart with some great examples) can be found here at the TTB website.
If the TTB chart doesn’t help, please check out the wonderful post published by the wonderful people at Ship Compliant, who have kindly highlighted the changes in the new form. Want more help? The legal team at BevLog have put together a nice description of “ARTAL” (an acronym standing for Allowable Revisions to Approved Labels”).
So, if you want to make changes to that age old label but didn’t want to go through another COLA process – it is time to rethink that strategy and get to updating that art.