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Expedites

Many years ago, it was common for TTB to issue label approvals immediately, on the day of submission.

That was a long time ago.

These days it is not so easy to get a quick approval, even when you really need one.

For many decades, until 2011, TTB had a fairly liberal procedure to expedite label approvals. Under these rules, we had a great track record of helping hundreds of companies cut the wait from a few weeks to a few days. To a large extent, the days of easy expedites are over, replaced by a rigid first-in-first-out regimen. Although it is clearly more difficult to expedite labels, as compared to the years before 2011, it is not impossible. We can work with you and TTB to find ways to reduce delays and avoid costly business interruptions.

The firm offers a wide variety of pricing plans and levels of service to meet your particular needs.

COLAs Online 

To submit your labels:

Email: colaserver@bevlaw.com
Fax: 202-478-5189
Mail: 2911 Hunter Mill Road, Suite 303 Oakton, VA 22124

We can make COLAs Online work better for you, because we know the rules. TTB has lots of rules (for using COLAs Online, in the CFR, at ttb.gov, unwritten, in the Beverage Alcohol Manual, etc.), and it can be difficult to get an optimal result unless you know many of these rules.

TTB/ATF has developed COLAs Online since about 2003. It is an all-electronic system for processing beer, wine and spirits labels. The new system can be quicker than the paper-based system that has been in place for at least 50 years. Lehrman Beverage Law, PLLC is committed to ensuring that the new and old systems will work well for you.

With the old, paper-based system it could take a week or more for your application to arrive in the right office, even with FedEx. By contrast, with the new system (after enrollment), you can have your application at the right office within 20-30 minutes after you start preparing it.

If you do not have an extra 20-30 minutes to spend on each label, if you are not familiar with TTB/ATF’s label rules, or if you are not familiar with how COLAs Online works,we can help. Instead of spending 20-30 minutes or more per label (reviewing your labels, scanning them to the right size and format, registering to use COLAs Online, filling out the online forms), for most labels all you need to do is submit legible labels to this office. Once you are properly enrolled as discussed at Requirements below, you can be done in as few as three clicks (forward to | colaserver@bevlaw.com | send). We can do the rest. Robert C. Lehrman has successfully and efficiently processed thousands of beer, wine and spirits labels over the past 25 years.

To demonstrate the benefits of COLAs Online, we are pleased to offer you two complimentary submissions. There is no fee and no obligation. To accept this offer, submit legible labels to colaserver@bevlaw.com. We will promptly submit your labels to TTB/ATF in the proper format and keep you informed.

Commitments. In processing your label, we make the following commitments. We will:

• Have an experienced attorney review your label before submission and alert you to any substantial complications.
• Prepare the electronic application in accord with TTB/ATF rules.
• Convert your labels into a form and format allowed by TTB/ATF.
• Submit your labels to TTB/ATF within a day of receipt.
• Notify you about the result within a day after TTB/ATF acts.
• Protect the confidentiality of your work and archive the approvals to CD (upon request, as an added protection).

Requirements. To take advantage of this offer, you need to do three things:

• Submit legible labels by fax, mail, expedited mail, or e-mail (colaserver@bevlaw.com). E-mail leads to the best results.
• Grant a power of attorney under TTB Form 5000.8. On this form, please complete items 12 and 13, then return to this office in duplicate.
• Provide a copy of your TTB/ATF permit.

Limitations. Please note the following limitations that apply to this offer:

• This offer is good for up to two label submissions per permit.
• We guarantee to comply with the above Commitments. There is no guarantee that TTB/ATF will approve your label.
• If the product requires a formula or other Pre-COLA Approval you must provide a copy.
• We would be happy to explain the relevant rules and regulations, to seek expedited approval (in as few as 48 hours), advocate approval of your label, or seek a use-up, but these services are not included in this complimentary offer and are available for a fee upon request.

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We look forward to showing you a fast, easy, economical way to do COLAs Online. For any questions about this offer, or about our regular fees and services, please contact Robert C. Lehrman at rclehrman@bevlaw.com or at the office.

TTB/ATF has developed COLAs Online since about 2003. It is an all-electronic system for processing labels, compared to the paper-based system in place for at least 50 years before. The new system can be quicker than paper. Lehrman Beverage Law, PLLC is committed to ensuring that the new and old systems will work well for you.

An overview of COLAs Online is here and a FAQ is here. We can make COLAs Online work better for you, because we know the rules. TTB has lots of rules (for using COLAs Online, in the CFR, at ttb.gov, unwritten, in the Beverage Alcohol Manual, etc.), and it can be difficult to get an optimal result unless you know many of these COLAs Online prototype screenrules. The internet makes it faster and easier for TTB to approve labels — and to reject them.

To demonstrate the benefits of COLAs Online, we are pleased to offer you two complimentary submissions. There is no fee and no obligation. To accept this offer, submit legible labels to colaserver@bevlaw.com. We will promptly submit your labels to TTB in the proper format and keep you informed.

	COLA Server	Do it yourself
Knows label rules		?
Knows COLAs Online rules		?
Handles paper and online applications		?
Already registered with TTB		?
Walk in to TTB when necessary		?
Scan labels and documentation into COLAs Online		?
Convert images to allowable size and format		?
Expedite urgent labels		?
Seek use-up on deficient labels		?
Archive electronic approvals		?
Less expensive than an hour of your employee’s time		?

Commitments. In processing your label, we make the following commitments. We will:

• Have an experienced attorney review your label before submission and alert you to any substantial complications.
• Prepare the electronic application in accord with TTB/ATF rules.
• Convert your labels into a form and format allowed by TTB/ATF.
• Submit your labels to TTB/ATF within a day of receipt.
• Notify you about the result within a day after TTB/ATF acts.
• Protect the confidentiality of your work and archive the approvals to CD (upon request, as an added protection).

Requirements. To take advantage of this offer, you need to do three things:

• Submit legible labels by fax, mail, expedited mail, or e-mail (colaserver@bevlaw.com). E-mail leads to the best results.
• Grant a power of attorney under TTB Form 5000.8. On this form, please complete items 12 and 13, then return to this office in duplicate.
• Provide a copy of your TTB/ATF permit.

Limitations. Please note the following limitations that apply to this offer:

• This offer is good for up to two label submissions per permit.
• We guarantee to comply with the above Commitments. There is no guarantee that TTB/ATF will approve your label.
• If the product requires a formula or other Pre-COLA Approval you must provide a copy.
• We would be happy to explain the relevant rules and regulations, to seek expedited approval (in as few as 48 hours), advocate approval of your label, or seek a use-up, but these services are not included in this complimentary offer and are available for a fee upon request.

To submit your labels:

Email: colaserver@bevlaw.com
Fax: 202-478-5189
Mail: 2911 Hunter Mill Road, Suite 303 Oakton, VA 2212

Media Mentions

Robert Lehrman has been cited as an authority on alcohol beverage law by: Time Magazine, The Washington Post, The New York Times, Reuters, Bloomberg, National Public Radio, The San Francisco Chronicle, The Boston Herald, The Boston Globe, The Daily Californian, The Los Angeles Times, The Swiss Broadcasting Corporation, The Virtual Absinthe Museum, Men’s Journal, The Augusta Chronicle, The Charlottesville Daily Progress, Gizmodo, Chicago Magazine, The Sacramento Bee, The Philadelphia Inquirer, Las Vegas Weekly, The Chicago Tribune, Reason Magazine, The Daily Beast, Wine & Spirits Daily, Dow Jones MarketWatch, Virginia Lawyers Weekly, SevenFiftyDaily, Beer Business Daily, SevenFiftyDaily, The New Jersey Law Journal, The BBC, The St. Louis Post-Dispatch and many others.

In 2016, Thomson Reuters published “Reflections on Thirty Years of Spirits Law Practice:  From a Few Score to a Few Thousand Distilleries” by Mr. Lehrman. This is part of the Aspatore — Inside the Minds series, a book entitled Moonshiner to Craft Distillery: Leading Lawyers on the Business of Distilling.

Events

Robert has participated as a faculty lecturer at CLEI’s Beer, Wine & Spirits Law Conference, discussing ATF Label Revocation Procedures. In 2010, Robert moderated a NABCA panel entitled “TTB and FDA: Working Side by Side to Regulate Alcohol Beverages.”

In 2014, Robert presented a speech about “Needs Correction: 9 Common Label & Formula Controversies for Spirits at TTB” at the American Distilling Institute conference in Seattle.

Throughout 2013-2016, Robert covered spirits labels, formulas and permits several times per year as a speaker (along with such legends as Jimmy Russell of Wild Turkey) at the Moonshine University, Louisville, Kentucky. In 2014 Robert presented “The Label from Hell” at ShipCompliant’s Wholesale Gathering in New York.

In 2015 Robert spoke at the American Distilling Institute annual convention in Kentucky, on “The Law of Handmade.”

In 2016 Robert joined a panel on what’s next for the industry, at USBevX in Washington, DC. Robert continued as a faculty member at the Moonshine University, speaking with new distillers on federal issues affecting spirits.

Robert C. Lehrman, Attorney

• • Longer bio.
  • Shorter bio.: Robert C. Lehrman is a lawyer at Lehrman Beverage Law, PLLC in metro Washington, DC. Since 1988 he has specialized in the federal law surrounding beer, wine and spirits, such as TTB permits, labels, and formulas. Together with Kubler and Lucid, Robert helped to legalize absinthe in the U.S., from 2004-2007, after a 95 year ban.

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