As Sri noted, the government shut down is causing a big headache for wineries looking for COLA (Certificates of Label Approval). This impacts new wineries like mine (Birdhorse) even more than established small wineries. When the news of the government shutdown hit, we sprang into action, figuring we could at least get our labels submitted into the queue in order to be near the top of the list once they started processing. Unfortunately, this is when we learned that someone needs to manually approve first-time registrants for access to the COLA online system! And since the government is shut down, there's no one to do even that. Therefore, the queue is building and we are basically up the creek.
Once the government reopens, we will have to go through the COLA registration process. This historically took about 6 days. Only after we've been granted an online account (despite having been permitted and registered with the TTB for months), then we enter the COLA queue. Historically, it took about 36 days for a wine label to be approved. Unfortunately, the TTB stopped processing COLA accounts as of 12/20 and wine labels as of 12/18. So, we'll have at least a month's backlog on top of the normal processing times. I just hope it's not worse.
This causes real operational problems for us. We have decided not to print and to wait for the COLA, because we can't afford a reprinting should the TTB have edits. The downside here is that we need to bottle in March. Typically, bottling and labeling can occur together in a nice, mostly automated fashion. In the increasingly likely event where we don't have approved printed labels in sync with our bottling time, we will have to bottle and then later manually affix our labels.
The government shutdown has not yet caused a top-line issue for us, but that is the next worry should it continue further into record territory.
https://www.ttb.gov/labeling/processing-times.shtml
https://www.ttb.gov/formulation/registrations-processing-times.shtml
https://www.ttb.gov/labeling/colas.shtml
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