It’s well into bottling season by now, and while there are plenty of larger, well-staffed wineries who bottle year-round out of necessity, for the smaller folks it’s a mad dash to get wine into bottle before harvest. Unfortunately, this year presents a major obstacle for those trying to use new labels.
As we all know, labels require approval from the federal government (COLAs). It is illegal to bottle wine without a COLA. While there are work-arounds to a certain extent (e.g. you can bottle shiners, unlabeled bottles, under a generic COLA), you cannot physically put an unapproved label on a bottle of wine. It’s illegal and no reputable bottler will do this for a winery and wineries with their own bottling lines should be prudent enough to follow suit.
Seeing as this is and has been standard practice, what’s the problem? COLA applications used to be of the snail-mail variety. But since the inception of COLAs Online, a system that allows wineries to submit federal label approval applications electronically, turnaround time has been quick. I never saw anything greater than one business week. Tops. Until 2011.
Early in the year (February 2, 2011), the TTB sent out a circular encouraging wineries to allow up to three months in advance for COLA approval. From less than a week to 90 days was a staggering difference. The reasons they gave were the “considerable increase in the number of applications” and “shrinking resources available to TTB”. For better or worse, this magnitude of advance planning is not in the DNA of many wineries. Although as my father always said, “Remember the six Ps: Prior Planning Prevents Piss Poor Performance.” Nothing could be truer now for wineries who anticipate needing a COLA.
To give credit where credit is due, the TTB revamped their system and now offer real-time average COLA processing times to the public. Also, their average processing time dropped by more than 66% not terribly long after the 90-day warning was issued. Although, I submitted a couple labels for approval just last week, right when the current average processing time shot back up to a frightening 36 days. Frightening because bottling schedules are getting filled up, harvest prep is already fast approaching, and it’s challenging (and sometimes unfair) to lock in a bottling date without knowing when your labels will be approved.
Personally, I refuse to go to print without approval. Plenty of wineries, however, will prematurely print their labels in an attempt to beat the clock. This can backfire if the COLA gets rejected. Then the winery is stuck with (a) a longer turnaround time, (b) labels they don’t want and/or can’t use, but were paid for, or (c) the possibility of extra work in applying for a “Use Up” permit, with the hopes that the TTB will take pity on them.
In just the last couple days, the turnaround time has increased to 38 average days for wine label approvals. It’s a bit of a moving target. Plus, it’s only an average, not a maximum. I’m guessing that there are plenty of other folks out there sweating the timeline, just like I am right now.