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Re: None

Wednesday, 03/29/2017 4:17:48 PM

Wednesday, March 29, 2017 4:17:48 PM

Post# of 81740
Here we go:

What is a COLA expiration date?

Certificates of Label Approval (COLA) that are “Approved” only expire if a date is displayed in the “Expiration Date” box on the COLA. Otherwise an approved COLA may be used indefinitely. Under certain limited conditions, COLAs are given “temporary approval” with an expiration (or termination) date.

TTB will issue a COLA with an expiration date when a label contains a minor error that does not warrant rejecting or returning the application for correction. This “temporary approval” gives the COLA holder a period of time to correct the label while being able to bottle and remove product in the interim.

If a COLA is given an expiration date, it also has qualification(s) on the certificate that outlines the reason(s) why it was given an expiration date. If the COLA holder still needs an approved COLA to bottle or remove product from Customs custody after the expiration date, he or she must obtain a new COLA which would include correcting the labels prior to resubmission. The item(s) that need to be corrected are located in qualification box of the expired COLA.

It is also important to note that the status of an Approved COLA changes to Expired in the Public COLA Registry and COLAs Online when the expiration date is reached. Expired COLAs may NOT be used to bottle or remove product from U.S. Customs custody.

https://www.ttb.gov/alfd/archive/alfd_newsletter_march10.pdf



So I guess the question is, will the current COLA, which does not have "100% Agave" on the label, suffice to cover the new bottles, which state "100% Agave" on the label, given that that added term is the reason why the old COLA was set to expire in the first place?