that shows a different brand name for the wine. The new brand name must not suggest the viticultural area name.

The prohibition on the use of geographic brand names in 27 CFR 4.39(i) contains an exception. A geographic brand name may be used on the labels of wines that are not eligible for the appellation of origin if-

• The name was approved for use before July 7, 1986, AND
• The bottler puts information on the label that makes it clear to the consumer that the grapes used did not come from the area suggested by the name.

It is the bottler's responsibility to assure that the wine in the bottle matches the claims on the label. If ATF discovers that a wine is ineligible for the appellation suggested by its geographic brand name, we will take corrective action. For example, we could require re-labeling of wines or cite violations of the labeling regulations.

ATF gives formal notice of proposed rules, including proposed viticultural areas, by publishing them in the Federal Register. We also give informal notice by sending press releases to wine industry publications, mentioning the petition in the A&T newsletter, and putting the Notice on our Web site http://www.atf.gov/alcohol/rules/
index.htm when we publish in the Federal Register. We generally allow a 60-day comment period on proposed viticultural areas after Notices of Proposed Rulemaking are published. Each notice contains instructions for commenting by mail, fax, e-mail, or Web-based form.

Anyone may petition for a change in ATF regulations under 27 CFR 70.701. If you want to petition for a change in the viticultural area designation process or the use of geographic brand names on wine labels, contact the ATF Regulations Division, Room 5000, 650 Massachusetts Avenue, NW., Washington, DC 20226.

More on "How To Avoid Common Pitfalls" When Applying for Permits

By Sandy Clark, National Revenue Center (513)684-7274

The National Revenue Center (NRC) processes permit applications for ATF regulated industries, nationwide. We've again identified some common mistakes made by companies applying, this time, for permits in our "high volume" areas - wholesaling and importing alcoholic beverages, and importing tobacco products. We offer these hints on what our customers can do to avoid the most common mistakes made during the application process:

• Applicants for alcoholic beverage wholesaler or importer basic permits must show the source of funds invested in the business in Item 8 (Owner Information) on ATF Form 5100.24, "Application for Basic Permit Under The Federal Alcohol Administration Act". This information must include the name and location (city and state) of the financial institution (bank, savings and loan, etc.) from which the funds were derived (or are currently located if this investment came from personal savings, loans or other similar means). If Item 8 is incomplete, the NRC can't process the application until we contact the applicant and obtain additional information. This routinely means delays in issuing the permit.
  

• Applicants for tobacco importer basic permits must include source of funds information in Item 13 on ATF Form 5230.4, "Application For Permit Under 26 U.S.C. Chapter 52, Importer of Tobacco Products". Item 13 is often completely overlooked by applicants and again this will routinely cause delays in processing applications and issuing permits.
  

Anyone needing help in obtaining or completing these, or any other permit application forms, should contact the National Revenue Center at 1-800-398-2282 or e-mail us at: natlrevctr@cinc.atf.treas.gov.