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The TTB’s New Exemptions for Pre-COLA Requirements & Formula Approvals

law-picThis past week, the TTB released Industry Circular 2016-01, which details exemptions for certain pre-COLA requirements for certain alcohol products.  The two pre-COLA requirements in question are formula approvals and laboratory analysis.  The TTB highly suggested that any individuals involved with bonded wineries, bonded wine cellars, tax paid wine bottling houses, beverage distilled spirits plants, breweries, or importers familiarize themselves with these updated regulations.  Domestic and imported wines derived from carrots, dried fruits, mead, maple syrup, onions, peppers, pumpkins, rhubarbs, sweet potatoes, or tomatoes are now exempt from previously required formula approvals.  Several types of imported blended whiskey, straight whiskey, and vodka no longer require pre-import letters or laboratory sample analysis.  Various domestic whiskies and vodka do not even need to provide their formula at all.  Some rums and brandies are also exempt.  Lastly, malt beverages that contain certain ingredients and use certain production processes are not required to follow previous formula procedures.  The TTB has issued these changes to ultimately cut down the length of approval processes for alcohol products to 10 days.