TTB Issues Guidance for Retention of COLA's by Wholesalers
TTB clarifies its policy with respect to a wholesaler's requirement to retain copies of Certificates of Label Approval (COLA's) for imported alcoholic beverages. Products in the wholesaler's inventory that are subject to this requirement are those for which the wholesaler holds the COLA and acts as the authorized importer. For products purchased from an authorized importer/COLA holder, the wholesaler will be given "a reasonable period of time to obtain a copy of the COLA" if requested.
Note, as suggested in the Guidelines, wholesalers using a U.S. Customs bonded facility to store inventory should conduct "spot checks" to verify that the COLA's for such product, for example, are in effect before withdrawal.
To access the Guidelines, January 5, 2006, as published on TTB's website, Click Here.