Revised 10/09/02

COLAs Online

C1: What is a COLA?
COLA stands for Certificate of Label Approval. It is also used for Certificate of Exemption and Distinctive Liquor Bottle Approvals.

C2: What is COLAs Online?
COLAs Online is the system used to electronically file Applications for and Certification/Exemption of Label/Bottle Approval(COLA) and track the status of applications submitted for approval.

C3: When will COLAS Online be available?
COLAs Online will be available for use in the Spring 2003.

C4: What are the objectives of COLAS Online?
The objectives of COLAs Online are to provide industry members a streamlined, more expedient and paperless means to obtain a COLA. The system will allow industry members to submit COLAs to ATF via the Internet, provide a way for ATF to review the application electronically and return approved or rejected COLAs to industry members electronically. The system will also provide an on-line capability for industry members to obtain status updates on electronically filed forms and allow the public to view approved COLAs, including the labels.

C5: Will I be required to file COLAS electronically?
No. The filing of COLAs electronically will be optional and we still
accept paper copies of the form.  

C6: What are the advantages to filing COLAs electronically?

• The eApplication is easier to complete.
• A decrease in the time it takes to obtain a COLA.
  
• The time to send an eApplication to ATF and the time for you to receive a response will be instantaneous.
  
• You will have fewer rejections for omissions of data or incorrect information because the system will not let you submit incomplete applications.
  
• You will have the ability to track the status of your eApplications while they are in the system.
  
• The system will be accessible 24 hours per day.
  
• If during the initial review of your eApplication problems are disclosed, rather than reject the application outright, you will be given the opportunity to make corrections within 8 calendar days.
  
• Applications will not be rejected outright, and corrected eApplications will receive priority consideration.
  

C7: What programs will I need to install on my computer in order to use COLAs Online?
COLAs Online is a web-based system and you will need to have access to the Internet. The system will support Microsoft Internet Explorer 5.0 and higher. You will need an email address in order to receive status notification about your eApplications. You will also need access to a scanner to submit attachments including labels, unless you receive them in an electronic format from your designer/printer.

C8: What is required to register for COLAs Online?
To register for COLAs Online, you will be required to complete a registration form, ATF F 5013.2, COLAs Online Access Request, in order to receive a user ID and password to obtain access to ATF's COLAs Online System. If you do not have signature authority or power of attorney to sign required documents on behalf of the company for which you are filing label applications, you will also need to complete ATF F 5000.8, Power of Attorney. If you already have a power of attorney, you will need to submit a copy of it when you apply to register to use COLAs Online. Send the required documents to the, Bureau of Alcohol, Tobacco and Firearms, Alcohol, Labeling and Formulation Division (ALFD), Washington, DC 20226.

C9: What are the steps for filing a label application electronically?
Listed below are some of the steps you will follow in order to file COLA applications electronically. Keep in mind that this project is a "work in progress" and some things could change as the system is being developed.

• You will access the ATF website at www.COLAsOnline.gov.
• You will log onto COLAs Online by entering your username and password (assigned during registration).
• Choose malt beverage, wine or spirits COLA. All proceeding questions will be defined by your choice in this step e.g. you will not be asked to supply a vintage date if you choose malt beverage.
• Certain information will be pre-populated (name, address, permit number, phone numbers), based on the data you supplied during registration.
• Enter other information, either choosing from drop down boxes or filling in the item.
• Attach a file with a label image (e.g. jpeg file). These can be files of electronic images from your printing company or scanned images of the paper label. There will be specifications on what files are acceptable and parameters regarding scanned images.
• You will be asked to verify the completed eApplication prior to submission.
• You may either save the eApplication for up to 30 days or submit it immediately. Submission must be by a person with signing authority or Power of Attorney.
• Once you submit the eApplication, you will receive an email verifying our receipt including the ATF ID number that was assigned to the application.
• Business rules will not allow submission if certain required information is omitted (e.g. brand name, net contents, no file attachment with labels).
• Once ATF takes action on your eApplication, the status will be changed and you will receive an e-mail that will inform you of the current status. "Needs correction" and "rejected" COLAs will indicate the problems that must be addressed before the COLA can be approved.
• Approved COLAs will indicate the class and type code, origin code, and qualifications or expiration date. The system will allow you to print out approved COLAs.
  

C10: Will I be able to use third party filers to file label applications electronically?
Yes. Third party filers (trade associations, law firms, and industry representatives and consultants) will be able to submit label applications on your behalf. The third party filers will need to obtain a power of attorney from the companies that they represent. They will also need to register with ATF and receive a User ID and a password.

C11: Will users be able to check the status of their eApplications?
Yes. You may log on at any time and your home page will show a listing of all eApplications you filed in the last 30 days and their current status. The system will also allow you to search for all eApplications you have submitted and will identify the current status - received, needs correction, approved, rejected. You will not be able to see this information for other company's submissions, or for your paper applications. Email notification of status changes in applications will be sent to the submitter. Therefore, if you use a third party filer to submit applications, they will receive the notification.

C12: What is the difference between the status "needs correction" and "rejected"?
The status "needs correction" means that the initial ATF review of your eApplication and label disclosed problems. Rather than rejecting the application outright, we will give you the opportunity to make the corrections within 8 calendar days. If you do not make the corrections within the established time frame or do not make all the required corrections, the application will be rejected and you will have to resubmit. This procedure will only apply to e filed applications. "Corrected" eApplications will receive priority consideration.

C13: How do I submit additional information with my COLA application such as a formula or organic certifications?
Attachments that are currently submitted in paper copy will need to be scanned into a file and saved as a word document or a PDF file.

C14: Will ATF electronically notify the States and Customs of approved COLAs?
No. This phase of COLAs Online will not interact with State or Customs
systems; however, all approved COLAs and images of the labels (both paper and electronically filed) will be posted on the ATF website, available for viewing by anyone, including the States and Customs. However, there will be a delay before posting the COLAs to the website. Users of COLAs Online and the public will be able to print copies of approved labels from the web page that can be submitted to States or to Customs.

We are involving the States and Customs in the development of COLAs Online and encouraging their participation; however, implementation of COLAs Online will not be delayed to accommodate all state and Customs integrations.

C15: If I am required to submit a paper copy of the COLA to a State or Customs, will the efiled version have my signature and the signature of an ATF representative?
We are exploring several options relating to signatures. One would be to have a statement in the applicant signature box on the COLA that reads "Signature on file with ATF." The applicant's name would appear in the adjacent box, as it currently does. Also, either the name or a facsimile of the signature of the ATF approving official will appear on the approved COLA. We plan to work closely with the State agencies and Customs to educate them on how our electronic labeling system will operate and what efiled COLAs will look like.

C16: Will COLAs Online reduce the amount of time it takes to receive label approval?
The human review process of the COLA application for compliance with the regulations will remain; however, eliminating the time it takes to send eApplications and return the COLA back to you through the U.S. Mail will shorten the process significantly. Also, the online application will have built-in validations to prevent many errors that are made by applicants on paper applications. Another process improvement will be the fact that in the new system, users will be able to "correct" a label application that will eliminate the need for most outright rejections, thus reducing the overall turnaround time for COLA approvals.

C17: Will I be able to file Formulas and Pre-Import approvals electronically?
No. This phase of the new electronic system will only deal with COLAs. Efiling of formulas, Statements of Process, Pre-Import approvals and Lab Analysis will be handled in a future phase of the project.

C18: Will COLAs Online improve the consistency of decisions made relating to
label applications?
Consistency of decisions made relating to label applications will only be addressed to a limited degree by a web-based system. COLAs Online will have business rules that will keep many incorrect or incomplete applications from reaching ATF. The "human element" will still be part of the label approval process due to the subjective nature of label regulations.

C19: How will COLAs Online affect customer service?
COLAs Online will not reduce your ability to interact with label specialists. The Customer Service Team will continue to handle your questions and concerns relating to labeling issues and face-to-face meetings with the labeling specialists or supervisors will still occur by appointment.