(Click each question to expand and show response)
1. What is COLAs Online?
Since about 2003 TTB/ATF has developed a computerized system to allow beverage companies to submit labels, and receive approvals, in a manner that is completely electronic and involves no paper. This is a massive and important change over the system that was in place for the preceding half a century.
For lots more information about COLAs Online and how to submit your labels via this firm, click here.
2. When did it roll out?
ATF started briefing industry members about its detailed plans in February of 2002. ATF said it would like to begin large-scale testing of the system toward the end of 2002, with implementation in early 2003. Federal law (the Government Paperwork Elimination Act of 1998) mandates that by October 21, 2003 federal agencies must allow the option to exchange and maintain information electronically.
3. Why would we need a law firm to help?
We can make COLAs Online work better for you, because we know the rules. TTB has lots of rules (for using COLAs Online, in the CFR, at ttb.gov, unwritten, in the Beverage Alcohol Manual, etc.), and it can be difficult to get an optimal result unless you know many of these rules. The internet makes it faster and easier for TTB to approve labels -- and to reject them.
4. What are the benefits?
5. Can I get instant approval?
No. You can move the application from you to TTB instantly, and TTB can move the approval or rejection back to you instantly. But it will still take 3 to 15 days on average in between.
6. What are the costs?
You will need a fair amount of familiarity with the rules, regulations and the COLAs Online system. If it takes about 20 minutes for an experienced person to complete a paper application and send it to Washington, on average, our rough estimate is that it COLAs Online prototype screenwill take no less time to prepare and send a COLAs Online application. Instead of cutting labels and taping them to paper, you will be busy scanning or formatting labels. TTB will not hand you a piece of paper that looks like a traditional COLA. You can only get a physical "certificate" if you print it out on your own printer. This could make it easier for other parties to do likewise and use your COLAs without your permission.
7. Do I need special equipment or training?
You need a basic computer with internet access. You will probably need a scanner to use the system properly, and a high speed connection would be helpful. No special software, other than a basic image-editing program, is required.
8. Can I do it myself?
Yes. If you have the time and patience to learn and use the new system, there is no reason why you could not use it yourself. But parts of it are tedious. For one simple approval, you could need to do all of the following: scan in your front label, scan in the back, scan in the formula, scan in the expedite letter, review all scanned images to make sure they are legible, crop them appropriately, indicate the actual size of each label, fill out the online form, submit. One thing that will not change is that you will need to be familiar with the relevant rules and regulations on labeling.
9. Do I have to use it?
No. TTB will continue to allow paper filing for a long time to come.
10. How do I decide between paper versus COLAs Online?
You can use both. If a supplier sent 50 paper labels today, it would probably be much easier to prepare 50 paper applications. The per label cost of shipping the paper would of course be negligible. Most of the form could be filled out once only, and then duplicated. It would take only a few minutes to affix each label set. So, for simplicity, let's say it would take 10 minutes per application in this scenario. By contrast, it is difficult to envision that it would take less than 15 minutes to prepare and submit each label with COLAs Online. On the other hand, if the same supplier sent one label by way of the newer system, it could appear on the specialist's desk within 20 minutes of receipt. Under the paper-based system it would take 20 minutes of preparation time and about a day of shipping time.
11. What can I do to get ready?
If you expect to seek help with your labels from time to time (from any third party such as an attorney or label service), you need to complete TTB's power of attorney form well in advance. The third party will not be able to provide much assistance with the COLAs Online system until this has been duly filed. This takes at least a week. You can download the power of attorney form (TTB 5000.8) here.