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Government Shutdown Clogs TTB Label, Formula, and Permit System for Wine Industry

On October 1, 2013, TTB announced a cessation in its operations, citing the lack of government funding as the reasoning. While the TTB website, www.ttb.gov, remains partially accessible, the ability to submit, review, or retrieve Certificate of Label Approvals (“COLAs”), Formula Approvals, or Permits is not permissible. This means that label, formula, and permit applications that were submitted to TTB prior to the shutdown remain at a standstill until government funding is restored. Additionally, the shutdown makes copies of previously approved labels, formulas, and permits inaccessible—and this includes the public COLA database that TTB maintains. Endusers can still, however, file electronic payments and returns for federal excise taxes and operational reports through the U.S. Department of Treasury.

What does the TTB shutdown mean for industry?

TTB is a division of the Department of Treasury and is the federal agency in the United States that—generally speaking—regulates wine, beer, and spirits. It is also the federal agency that grants pre-market approval to labels, formulas, and permits of TTB-regulated beverages and beverage producers, importers, wholesalers, and distributors. The shutdown means that no new labels or formulas can be submitted to TTB for approval and no new alcohol beverage-related permits can be granted. In its announcement, TTB also noted that no personnel will be available to respond to telephone calls, e-mails, faxes, or other communications. Essentially, this means label, formulate, and permit approvals will be backed up for many weeks, if not months, to come.

Some outside publications have noted that the shutdown has been particularly egregious to importers of wine, who need an active COLA for wine imports to be released from Customs ports. See Shutdown Affecting Wine Importssee also TTB Shutdown Means Wine Label Slowdown. Without a valid COLA, Customs will not release TTB-regulated beverage products from its custody.

For more information on wine or alcohol law, labeling, advertising, or TTB matters, please contact Lindsey Zahn.

DISCLAIMER: This blog post is for general information purposes only, is not intended to constitute legal advice, and no attorney-client relationship results. Please consult your own attorney for legal advice.

Lindsey A. Zahn


Lindsey is the founder and author of On Reserve: A Wine Law Blog. She is an alcohol beverage and food attorney and is admitted to the New York State Bar.

{ 5 comments… add one }
  • Chris Kammer October 16, 2013, 11:48 AM

    Thank you for getting the word out regarding the label issues with TTB , I foresee a large backlog of applications once the government gets back to work that could lead to several months for a label to be approved

  • Lindsey A. Zahn Lindsey A. Zahn October 16, 2013, 12:47 PM

    Hi Chris — thanks for the comment. I agree: It is looking like the label approval system will be backed up for a while (especially for wine).

  • Steve Burch October 16, 2013, 1:05 PM

    Any guesses on how long? I am telling my customers to expect at least 60 days. Hey Chris. Been a while. Give me a buzz when you get a chance. Same cell #

  • Lindsey A. Zahn Lindsey A. Zahn October 16, 2013, 9:25 PM

    Hi Steve — as of late today, TTB’s label, permit, and formula submissions websites are back up and running.

  • Chris Kammer October 17, 2013, 5:27 PM

    HI Steve & Lindsey,

    Spoke with TTB this morning, at the moment its 36 calendar days for a wine label approval.

    Steve – good to hear from you, I’ll give you a call later today


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