If you’ve ever used TTB’s Online Services, like COLAs Online or Formulas Online, you’ve probably found yourself frustrated with the unintuitive interface, unfamiliar (or easily misunderstood) standards, and arcane terminology. But that’s only the beginning of possible frustrations – even after wading through the appropriate service, it can feel like TTB Specialists reject submissions for small, meaningless issues. Given that distilled spirit plant proprietors can only legally sell products approved by the TTB, the pressure to get through these processes – and through the TTB Specialists – can feel immense.
That pressure can feel heavier still when you learn that misuse of Online Services can prompt an audit by the TTB. In one recent case, a DSP submitted the same label dozens of times, each time with errors. Ultimately, those red flags led the TTB to the DSP’s doorstep for a very thorough audit – most proprietors’ worst fear. In this case, the DSP in question had been using DISTILL x 5 to track and manage their operations for many years and had easy access to all the records that the investigators required to avoid any fines or penalties, but that isn’t the case for every distillery.
It’s worth remembering that the stress is felt on both sides. As recently as five years ago, approvals often took 30 days or longer; today that average is more like 3-7 days. TTB Specialists are under increasing pressure to approve submissions quickly and accurately, applying the Code of Federal Regulations and Beverage Alcohol Manual to an infinitely varied set of formulas and labels. It’s not an easy task, but while it feels like a bureaucratic nightmare for distillers it’s important to remember that Specialists’ jobs are to protect the consumer and ensure transparency across the industry.
The process of submitting (and revising) COLAs and formulas shouldn’t be adversarial; a little preparation and sound guidance goes a long way. Making an effort to ensure your submissions are compliant to begin with can greatly reduce, if not eliminate, a protracted back-and-forth. If your submission is rejected, engage with TTB in good faith – if you don’t understand why your submission wasn’t accepted, call them and ask! Chances are good that you’ll get information to help avoid another round of failed approval.
Alternatively, hire Fx5 Consulting and leverage our decades of combined experience in interfacing with TTB and other regulators to get your submissions approved the first time (or the next time!). Whether you need quick help with a label or a full internal audit, we’re here to help cover your assets and let you get out of the TTB quagmire and back to your business.
Tyler Derheim is Fx5’s in-house consultant, using his expertise to help distilleries of all sizes make it easier to make great things. Tyler first entered the regulated beverage industry in 2010, when he started working harvest and crush at a midsize winery in Slovenia. After returning to California in 2017 he joined a startup DSP, with responsibilities for formulation, production, compliance, lab services, and more. In 18 months, he led the DSP from mason jars and buckets to tankers and trailers, then moved into a freelance consulting role, helping distilleries of all sizes with every aspect of production, operations, and compliance. A long-time Fx5 user, Tyler brings a wealth of experience unmatched in the industry.