COLAs Online

To: Distilled Spirits Plants, Breweries, Wineries, Taxpaid Wine Bottling Houses, Importers and Others Concerned

What is the purpose of this circular?

This circular announces that the Bureau of Alcohol, Tobacco and Firearms (ATF) is currently developing a system for the electronic filing/processing/approval of ATF Form 5100.31, Application for and Certification/Exemption of Label/Bottle Approval (COLA). The Government Paperwork Elimination Act (GPEA) requires that Government agencies offer e-filing solutions to their customers by October 2003. In order to comply with the GPEA, ATF has been looking into ways to accommodate the electronic submission and approval of COLAs. In September 2001, we awarded a contract to a vendor who is currently developing a system to automate the COLA process. This new system is known as COLAs Online. The system is expected to be complete and ready for use during the early part of 2003.

What is the objective of COLAs Online?

The objective of COLAs Online is 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, as well as provide a way for ATF to review the application electronically and to return approved or rejected COLAs to industry members electronically. The system will also provide an online capability for industry members to obtain status updates on electronically filed forms and allow the public to view approved COLAs including the labels. Some delays in posting the COLAs to the Web site are anticipated.

Will I be required to file COLAs electronically?

No. The filing of COLAs electronically will be optional. We will still accept paper copies of the form.

What are the advantages to filing COLAs electronically?

• The eApplication will be easier to complete.
  
• The time it takes to obtain a COLA will decrease.
  
• Transmission of eApplications to ATF and responses will be virtually instantaneous.
  
• The system will prevent submission of incomplete applications; therefore, there will be fewer rejections for omissions of data or incorrect information.
  
• The status of eApplications can be tracked while they are in the system.
  
• The system will be accessible 24 hours per day.
  
• If problems are disclosed during the initial review of your eApplication, 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.

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 e-mail 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.

Will I need to register with ATF in order to gain access to COLAs Online?

Yes. When you register, you will receive a user name and a password. You will need to provide your company name and current address as it appears on your plant registry, basic permit, or brewer's notice. If the name or address appearing on these documents has changed or is not accurate, you must notify the ATF National Revenue Center in Cincinnati, Ohio, at 1-800-398-2282. Inaccurate information could delay the registration process; therefore, we recommend that you make any necessary corrections NOW.

While we are exploring the option of online registration, registration will occur by paper application. We plan to begin registration in the fall of 2002 and we will advise you of the procedures.

What are the steps for filing a label application electronically?

Listed below are some of the steps to follow if you file COLA applications electronically. Please keep in mind that this project is a work in progress and expect changes as the system is being developed.

• Access the ATF Web site (www.atf.gov) and select the "COLAs Online" link.
  
• Logon to "COLAs Online" by entering your user name and password (assigned during registration).
  
• Choose one of these options: malt beverage, wine, or spirits.
  

All questions will be defined by your choice in this step. For example, you will not be asked to supply a vintage date if you choose the malt beverage application.

• Enter information as required, either choosing from drop down boxes or filling in the item.
  

Certain information will be pre-populated (name, address, permit number, phone numbers), based on the data you supplied during registration.

Business rules will not allow submission if required information, such as brand name, net contents, or the label is missing.

• Attach a file with a label image (e.g., a "jpeg" file).

These can be files of electronic images from your printing company or scanned images of the paper label. Specifications on what files are acceptable (types, sizes, number of attachments) and information on the parameters of scanned images will be provided.

• Verify accuracy of the completed eApplication prior to submission.
  
• Save or submit the eApplication.
  

You may save it for up to 30 days or submit it immediately. Only a person with signing authority or power of attorney may submit the COLA.

What can I expect after filing an eApplication?

• You will receive an e-mail verifying receipt. It will include the ATF identification number assigned to the application.
  
• Once we take action on your eApplication, you will receive an e-mail informing you of its status. If your application needs correction or is rejected, the e-mail will identify the problems that must be addressed before the COLA can be approved.
  
• If your COLA is approved, you will be able to print it out. It will closely resemble paper copy COLAs and indicate the class and type code, origin code, and qualifications or expiration date.

Will I be able to use third parties to file label applications electronically?

Yes. Third party filers, such as trade associations, law firms, and industry representatives and consultants, will be able to submit label applications on your behalf. Such third parties 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 name and a password.

Will users be able to check the status of their eApplications?

Yes. You may logon at any time, and your home page will show a listing of all eApplications you filed in the last 30 days, along with their current status. The system will also allow you to search for all eApplications you have submitted and to identify their current status-received, needs correction, approved, rejected. It will not allow you to check the status of paper copy applications. You will not be able to see information on other companies' submissions.

E-mail notifications of status changes in applications will be sent to the submitter; therefore, if you use a third party filer to submit applications, he or she will receive the notifications.

What is the difference between the status categories of "needs correction" and "rejected"?

The status "needs correction" means that the initial ATF review of your eApplication and label revealed problems. Rather than reject the application outright, we will give you the opportunity to make 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.

How do I submit additional information, such as a formula or organic certifications, with my COLA application?

You must scan the type of attachments that are currently submitted with paper applications into a file or submit them as documents. You must upload them as part of the eApplication process.

Will ATF electronically notify the States and U.S. Customs Service (USCS) of approved COLAs?

No. This phase of COLAs Online will not interact with State or USCS systems. However, all approved COLAs and images of the labels (both paper and electronically filed) will be posted on the ATF Web site and be available for viewing by anyone, including the States and USCS. 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. The States and USCS have been notified of the development of COLAs Online, and we encourage their participation. However, accommodation of State and USCS integrations will not delay implementation of COLAs Online.

If I am required to submit a copy of the COLA to a State or the USCS, how will my electronic signature and that of the ATF representative be reflected?

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 of or a facsimile of the signature of the ATF approving official will appear on the approved COLA. ATF will provide information on what e-filed COLAs will look like and on the operation of our electronic labeling system to State agencies and USCS.

Will COLAs Online reduce the amount of time it takes to receive label approval?

The human element of the review process of COLA applications remains. However, eliminating the time it takes to send and return COLAs through the U.S. Postal Service is expected to shorten the process significantly. Also, the online application will have built-in validations to prevent many errors made by applicants on paper applications.

Finally,the overall turnaround time for COLA approvals should be reduced, because users will be able to "correct" label applications and avoid the need for most outright rejections.

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. E-filing of formulas, statements of process, pre-import approvals, and lab analyses will be handled in a future phase of the project.

Will COLAs Online affect the consistency of decisions made relating to label applications?

COLAs Online should have little impact on the consistency of such decisions. Although COLAs Online will have business rules that keep many incorrect or incomplete applications from reaching ATF, the human element will remain part of the label approval process due to the subjective nature of label regulations.

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. Face-to-face meetings with the labeling specialists or supervisors will still occur by appointment.

Who should I contact concerning this circular?

If you have any questions concerning this circular, you can e-mail Bill Moore, Program Manager, at WTMoore@atfhq.atf.treas.gov. You may also follow our progress on the ATF Web site at www.atf.gov/alcohol/colasonline.htm.

Bradley A. Buckles,

Director