If you are submitting a COLA that is very similar to one that has been previously approved, perhaps you could reference that previously approved COLA in your application to get a faster approval. For example, if nothing on the label changed but the varietal or vineyard, then it should be easier for the reviewer to approve.

A relocation of an importer to a different city shouldn't require the printing of new labels for its entire portfolio and the submission of new COLA applications which is an extremely expensive process as well as time consuming for both TTB and the importer.A notification letter to TTB should be sufficient.

Should be automatic for a specific period
(perhaps 6 months) without requiring a new lab analysis and / or COLA application provided the manufacturer certifies there was no change to the product and the prior importer authorizes its use.

What is the true purpose of having to list each individual ingredient and the corresponding percentages when it is already listed on the formula containing the required step-by-step method of production? It is obviously a time consuming process.

Full review upon submission, and that's it.

The COLA system is extremely valuable not only for assuring compliance prior to launch but also for access by states to the database. We don't want to see a pure FDA approach where pre approval is ended along with the electronic file. That being said much can be done to free up staff for higher level work.

In some instances TTB wil have unwritten policy with regard to the use of certain wording, illustrations, etc. that appear on a label. Depending upon the specialist reviewing the label you may get a rejection or an approval subject to their interpretation. TTB bottom drawer policy should be consistent and made available to specialist as well as industry. Continuing education for the specialist is key and should be a must.

We have received rejections on labels that were previously approved under the Federal Import Permit of multiple importers. For the TTB to say that "the labels were approved in error" is tough to swallow given the fact that the product or products have been in the marketplace with approved labels for years.

Too often, labels are sent back for correction after the discovery of the very first error. Upon correction and re-submission, the TTB finds additional reasons to reject the very same label, requsting additional corrections.

Must e-mail the TTB laboratory to find out when a product analysis has been completed and sent to the TTB Formulation Division for issuance of the pre-import letter. There have been occasions when the TTB Lab has advised that a product analysis has been completed and forwarded to the Formulation Division but the Formulation Specialist tells us that they have yet to receive the analysis from the Lab.

A mistake is one label...once TTB approve several, it is policy.

Many labels are formated in high resolution to preserve the image quality and clarity of the label. Reducing the file often distorts the label resulting in return label applications requesting image corrections.

Many foreign suppliers send their labels in .pdf format.

There should be a way to submit minor changes toa label once it is already in the cue, without withdrawing/pulling the entire submission. You then have to upload the entire submission and be place at the end of the line (as if it is a new submission).

Questions whether by email of phone should be answered in a timely manner. Most go unanswered for days. If it can be done for wine you can do it for other commodities as well.

If there is a mentality among examiners that it is "fun" to catch little glitches and slow down the process, that psychology should be discouraged to streamline the process and move approvals, and the collection of more tax revenue, through the system.