The COLA (TTB F 5100.31) for wine: what TTB checks and how to avoid corrections

Form

TTB F 5100.31, Application for and Certification/Exemption of Label/Bottle Approval (a “COLA”)

Who files

The bottler or importer of the wine

Where

COLAs Online

TTB fee

None

TTB median review

3 days (85% within 15 days), per TTB’s processing-times page

Rule

27 CFR part 4 (wine labeling)

What happens after you file

TTB approves the application, or returns it as Needs Correction. TTB’s FAQ says you then have 30 calendar days to fix it; if you don’t, the status becomes Rejected, and you can file a new application later. Approval isn’t guaranteed, and nobody can promise it.

Points that most often need correcting

• Sulfite declaration

  “Contains sulfites” when sulfur dioxide is 10 ppm or more (27 CFR 4.32(e)).

• Vintage needs an appellation

  A vintage date requires an appellation of origin, and the grape-percentage rules for that appellation (27 CFR 4.27).

• Varietal names

  One varietal name needs at least 75% of that grape (with listed exceptions); two or more need percentages (27 CFR 4.23).

• Alcohol content

  Stated as required for the wine’s class (27 CFR 4.36).

• Name and address

  The bottler or importer statement must match the permit (27 CFR 4.35).

• Health warning

  Exact wording and format: “GOVERNMENT WARNING” in capitals and bold (27 CFR 16.21, 16.22).

Rule-based check points from the regulations cited; not TTB statistics.

Step by step

1. Finish the artwork. Final label images, at actual size, every panel that will be on the container.
2. Pre-check every mandatory statement. Brand, class/type, alcohol content, net contents, name and address, health warning and any statements your product needs.
3. File in COLAs Online. Submit TTB F 5100.31 with the label images. TTB charges no fee.
4. Answer corrections fast. If TTB returns it as Needs Correction, you have 30 calendar days to respond, or the application is rejected.

Related

• TTB F 5120.25, bonded winery application
• TTB F 5120.17, Report of Wine Premises Operations
• TTB F 5000.24, Excise Tax Return
• TTB F 5120.29, wine formula
• TTB F 5000.8, Power of Attorney
• Deadline calendar
• Glossary of terms

Sources

Checked Oct 28, 2026. Rules change; always confirm with the current regulation or TTB before you rely on a date.

1. 27 CFR part 4 (wine labeling)
2. 27 CFR 4.32 (mandatory label information, wine)
3. 27 CFR part 16 (health warning)
4. TTB: COLAs Online and Formulas Online FAQs (C23, Needs Correction)
5. TTB: eApplication statuses in COLAs Online (PDF)
6. TTB: Label processing times

Questions