When and How to get a COLA Waiver

By - November 25, 2016 | Alcoholic Beverage Law | Email Rob Pinson

Obtaining a COLA (Certificate of Label Approval) from the TTB can be a time-consuming process that’s difficult to sync with the rest of your operations. But here’s a little-known fact: if you are importing alcoholic beverages for use at a tradeshow, or to give out samples for soliciting orders, you may be eligible for a COLA waiver.

COLA waivers can be requested by submitting a formal letter to the TTB. The letter must guarantee that the products in question will meet these compliance requirements before reaching a U.S. port:
• The products will be imported by the holder of a Federal Importer’s Basic Permit (you also need to include the permit number)
• All applicable taxes and duties will be paid
• The imported products will have the following labels:
o Government Warning Statement (Code of Federal Regulations, Title 27, Subpart 16)
o Purpose label (e.g. “For Trade Show Purposes Only – Not for Sale”)
o A sulfites disclaimer for eligible wines (e.g. “CONTAINS SULFITES”)

The letter also has to provide information regarding the details of the products you need waivers for, including:
• The purpose for importing and for requesting a waiver (for tradeshows or other events, include dates and locations)
• The class, type, and quantity of each alcoholic beverage product
• The country of origin for each product
• The brand name of each product

The TTB accepts these waiver requests by both email and fax (202-453-2970). To make the process even faster and easier, I recommend using this official template provided by the TTB (this opens a MS Word file you can save and modify).

Robert Pinson

Robert Pinson

Robert “Rob” Pinson concentrates his practice in the areas of business law, tax law, estate planning, alcoholic beverage law and campaign finance law. As a Tennessee tax attorney, he has represented clients in stock and asset sales, tax audits and tax disputes. He also regularly goes before the Tennessee Alcoholic Beverage Commission and numerous Beer Boards on issues related to Tennessee alcohol laws. In addition, he has advised clients on tax strategy, estate planning, asset protection and campaign finance reporting.
Robert Pinson
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