Friday, April 1, 2011

Alcohol and Tobacco Tax and Trade Bureau (TTB)

Wines and Vines

News Headline March 31, 2011

TTB to Wineries: Help Us Help You

Online apps mean faster service for label approvals, AVAs and more

by Jane Firstenfeld
wine labels
Consumers use wine labels to differentiate between options. Source: TTB
    Washington, D.C.—Since Jan. 1, 2011, the Alcohol and  
    Tobacco Tax and Trade Bureau (TTB) has received
    37,960 applications for label approvals. Of these, 
    31,032 were for wine labels. “By comparison, for 
    the same period last year, we received 32,117 label 
    applications, of which 26,763 were for wine,” 
    according to Thomas Hogue, TTB congressional 
    liaison and acting media representative. 

   “We’ve been seeing an increase in wine COLAs  
    (certificate of label approval) over the years,” 
     said Hogue, whose career at TTB began in 1991,
    when he was a field inspector for what was then 
    the Bureau of Alcohol, Tobacco and Firearms. 
     More recently, he served as backup for long-
     time media representative Art Resnick, who 
     retired last October and has yet to be replaced. 



    The ever-increasing workload has prompted the
    TTB to implement changes in its operations, to 
   streamline and speed up processes like COLA and
   AVA approvals. Average processing time for COLAs
    is now just 20 days, according to the TTB’s weekly 
   COLA statistics update. COLAs are required for any
    wine (or other alcoholic beverage) before it is 
    released for sale. Hogue told Wines & Vines that 
    craft beer COLAs are another fast-growing category.

TTB has been accepting online COLA applications for some years, and this year has upgraded the system so COLAs Online users may now set authentication questions and answers and modify their registration through the portal.

The bureau issues a quarterly e-newsletter, available through The most recent edition discussed the correct use of “Fanciful Names” on labels. “A fanciful name is a term used in addition to the brand name for the purposes of further identifying a product,” it explained. This could be as simple as the addition of “rosé wine,” or a proprietary name for a blended wine or varietal. TTB has posted a useful PDFthat illustrates options for many styles of wine labels.

Tools such as these make it easier for both TTB and its users, Hogue said, by speeding up the process. He pointed out that TTB is an agency of the U.S. Department of the Treasury, and as such “We want to help the economy. Our folks do our absolute best” to help industry members. “We want to do whatever we can to help them get their products to market.”

Comments are welcomeOne heavily trafficked area of the TTB website solicits public comment about proposed changes to regulations, and applications for new or revised AVAs. 

Here, readers can review the actual texts being considered for legal adoption, submit comments pro or con, and read those of other interested parties. At the moment, comment periods are closed for all proposed rules while the bureau considers its decisions about, for instance, Notice No. 116—Addition of New Grape Variety Names for American Wines. 

The comment period for No. 116 expired March 21, but not before drawing some 67 public opinions, mostly from winery principals. A comment fromDavid Gates, VP vineyard operations at 75,000-case Ridge Vineyards, Cupertino, Calif., endorsed a request from PS I Love You to recognize Petite Sirah and Durif as synonyms, based on genetic evidence provided by Dr. Carole Meredith at the University of California, Davis.

Applications for new or altered AVAs or subappellations can stir up virtual wars of words, and may send applicants back to the drawing board, as happened during a years-long conflict about adding a Calistoga subappellation in Napa County. Finally settled in 2009, this is the kind of process that TTB would like to avoid.

Hogue urged industry members considering AVA applications: “Put together a proposal that meets the regulations, and work out the kinks with people who might object” before submitting the proposal. The mandatory period for public comment remains vital, however. “We want to know about problems and address them. If we get something that is (already) worked out, with everyone on board and without negative impact, that’s great,” he said.

Regarding AVAs, he said, “We assume they are of value to the industry, or they wouldn’t spend the effort” to complete the arduous, time-consuming and expensive process required to define specific American Vineyard Areas.

Of course, using a new AVA on your wine labels will require new COLAs as well. Hogue urged the wine industry to use the tools provided by TTB. “The more we can automate, the more we can maintain our level of service,” he said.

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