Elimination of Certain Pre-COLA Product Evaluation Requirements (Formulas or Laboratory Analysis) for Certain Alcohol Beverage ProductsTo: Proprietors of Bonded Wineries, Bonded Wine Cellars, Taxpaid Wine Bottling Houses, Beverage Distilled Spirits Plants, Breweries, Importers, and Others Concerned. PURPOSE This circular amplifies Industry Circular 2007-4, "Pre-COLA Product Evaluation," by announcing that: - TTB is eliminating pre-COLA evaluation requirements (i.e., formulas and/or laboratory analysis) for certain domestic and imported wines and distilled spirits products;
- TTB is separating and republishing the charts first published with Industry Circular 2007-4 as discrete guidance documents that can be updated individually as changes are made to formula requirements. Industry Circular 2007-4 will remain in effect, but the charts may be updated on an ongoing basis as formula requirements are revised.
BACKGROUND As part of its review of applications for certificates of label approval (COLAs) for distilled spirits, wine, and malt beverages under the Federal Alcohol Administration Act, 27 U.S.C. 205(e), TTB requires pre-COLA analysis of certain alcohol beverage products. Furthermore, TTB regulations in 27 CFR parts 5, 19, 24, and 25 require formula review for certain alcohol beverages. Industry Circular 2007-4, dated September 11, 2007, sets forth additional information about those requirements. For some alcohol beverages, TTB requires a formula to determine whether a proposed label identifies the product in an adequate and non-misleading way. Pre-COLA product evaluation entails a review of a product's ingredients and production process and also may include a laboratory analysis of a product sample. The type of pre-COLA product evaluation required for a particular product depends on that product's formulation and origin. List of Products Requiring Pre-COLA Evaluation TTB maintains three (3) commodity-specific charts, one each for wine, distilled spirits, and malt beverages, that reflect the current pre-COLA evaluation requirements for the listed products. Please be advised that, because the requirements for pre-COLA product evaluation for a particular type of product may change, it is important to visit the TTB website for the most current information. In addition, the charts are provided as general guidance. Particular circumstances may dictate the need for a pre-COLA product evaluation for a specific product even though no such requirement is listed in the charts. CONTACT INFORMATION If you have any questions concerning this circular, please contact the Advertising, Labeling and Formulation Division at 1-866-927-2533 or at Submit an Online Inquiry. 
John J. Manfreda
Administrator
Alcohol and Tobacco Tax and Trade Bureau |
