841000:RJE/JJV

April 29, 2003

Dear Industry Member:

Within the next few weeks, the Alcohol and Tobacco Tax and Trade Bureau (TTB) will unveil an electronic filing system which will enable the submission of the Application for and Certification/Exemption of Label/Bottle Approval (TTB F 5100.31) via the Internet. This innovation will improve the submission and review process for alcohol beverage labels by bringing an expedient and paperless means of seeking Federal label approval. Labels making organic claims are no exception and will undoubtedly reap such benefits through e-filing. Given the unique circumstances surrounding labels making organic claims however, users must take a few additional steps to capture the full benefits of this system.

Labels that make organic claims must undergo a concurrent review from both TTB and the United States Department of Agriculture (USDA). In order to expedite such a procedure, TTB must be in a position to immediately determine when a label making an organic claim is received. Therefore, we kindly request that you contact the Advertising, Labeling and Formulation Division (ALFD) by email at alfd@ttb.treas.gov or by phone at 1-866-927-2533 once you have submitted an e-application that contains an organic claim. In order to provide you with the best possible service, please be prepared to reference the 14-digit TTB ID number which will be sent to you via email and which will also appear on the submission confirmation screen.

Those who submit applications using COLAs Online should also expect minor changes in the return of USDA's decisions. Currently, returned paper-filed applications are accompanied by a separate decision from USDA regarding their compliance with the National Organic Program regulations. With COLAs Online however, electronically-filed applications will incorporate USDA's remarks directly on the returned e-application. For labels given an Approved status, USDA's remarks will be included in the "Qualifications" section of the returned e-application details. For labels given a Rejected status, USDA's remarks will be included in the "Reasons for Correction/Rejection" section of the returned e-application details. Labels given a Needs Correction status will incorporate USDA's decision in the "Reason" section of the "Application Needs Correction" screen. Consolidating the decisions of TTB and USDA will furnish a more clear, concise, and comprehensive summary of the e-application's review. This will facilitate the correction process by clearly identifying necessary changes, therefore allowing applicants to bring their labels in compliance with both TTB and USDA regulations.

Compliance, afterall, is the principle objective driving the interaction between government and its regulated industries. COLAs Online will serve to facilitate such an interaction in a most convenient and technologically advanced environment. The benefits gained from such a system are limitless. While submitting organic applications may require a few additional steps to ensure the success of this process, it is our sincere hope that you find in this innovative system a means by which to more effectively and efficiently carry out your business.

To learn more about COLAs Online, please visit www.ttbonline.gov. If we can of personal assistance, please contact us at 1-866-927-ALFD.

Sincerely,

Karen T. Freelove
Chief, Advertising, Labeling and Formulation Division