ALFD Newsletter June 2009

What Does it Mean?

Trade Name
A trade name, also called a DBA, is a name you may choose to use when conducting business other than the official business name listed on your permit. A trade name must be approved and properly registered with the National Revenue Center prior to use.

Each time you create a new application in COLAs Online, your official business or corporate name and premise address from your basic permit is automatically populated on the application. This feature exists to save time and reduce errors. However, COLAs Online only displays the name recorded on the basic permit and does not track various trade names your firm may have added to the permit.

If you are using one of your registered trade names on the label in the bottler’s statement (for domestic products) or the importer’s statement (for imported products), you must show this name in the field labeled “Trade Name”. If the bottler’s or importer’s name on the label is your official business name as shown in Step 2 of the application, a Trade Name field entry is not required, and this field should remain “blank.”

If your label is returned and you see this correction:

“The company name or the trade name on your e-application is not the name or trade name listed in the address statement on your label.”

either the trade name was not entered, or the trade name field does not match the Bottler or Importer statement on the label.

Greetings!

Welcome to the June 2009 installment of COLAs Online eNews, with information, tips, and reminders that may get you from the business office to the garden or the fishing pond just a little more quickly. Make the best of eNews. Help us address your COLAs Online concerns by sending comments and ideas for future issues to COLAsONLINEeNews@ttb.gov.

You Aren't the Only One Who Asked Us...

Sometimes when you submit your label application, you may want to include some extra information or provide an explanation for something that appears on your labels. Or perhaps an application has been returned for a correction, and you would like to address the matter with a Specialist.

Quite often people incorrectly use the “Special Wording” section in Step 3 to make comments to the Labeling Specialist. However, this area should only be used to include: any wording appearing on materials affixed to the container (other than the labels attached to the application); any wording embossed on the container; translations of foreign language text appearing on the labels. Once the application is approved, the document becomes public information. Any comments that appear in the special wording section are visible as part of the approved application.

Comments should instead be included in a word document, or scanned into a file, and uploaded under the “Upload other attachments” section in Step 3. Unlike label images, acceptable file types for attachments include: .doc, .txt, .pdf, .jpg and .tif. An attachment is only visible to TTB personnel and the company which submitted the application.

Tip of the Month

Remove all “white space” from around the label image before uploading your file.

White space is any extra space surrounding your label image that is not part of the actual label. This extra space often includes measurements or printer’s proof information. Or it can be caused when scanning your label with a larger sheet of paper behind it. The white space then becomes part of the image (see Fig. 2).

We require that labels be uploaded without any extra space surrounding them, as each will appear on the container. The printable version of the application is created by applying the dimensions you enter to the images that are uploaded. If there is white space, the entire image is resized, not just the label (see Fig. 3). The label needs to be shown in the correct size on the printable version, so we can ensure the correct type sizes have been used.

How can you check for white space? Go to the “Successfully uploaded” section on the Upload Label Images page and open the file by clicking on the file name underlined in blue. Place your cursor to the side of the image, but not on the image, and right-click with your mouse. Then choose “Select All”. This will highlight the image, including any white space that may appear around the image. Don’t see the “Select All” option? Keep moving the cursor away from the image and right-click with your mouse until the option appears. If you see that more than your label is highlighted, you have white space.

White space can be eliminated by using the “crop” feature available in many software programs. If you have an odd shaped label, it will be impossible to crop off all of the white space, so make sure you crop as closely as you can to the label edges. Checking for white space and removing it before submitting your application will help you obtain application approval more quickly.

How Do I?

Labels that will be etched, embossed, or painted directly onto the container, or that are clear acetate, must be submitted with a photograph of the container. Label images of what will be etched or painted on the bottle should be uploaded under the “Upload label image” section of step 3 of the COLA application. In addition, photographs must be uploaded under the “Upload other attachments” section. Printer proofs or graphic artwork renderings of etched bottles are also acceptable.

Photos should clearly show each side of the container that contains label information. We will use this to determine if all mandatory label information is readily legible on a contrasting background. When using clear labels or etched bottles, the color of the container and the liquid content may affect the legibility and contrast of mandatory information.

Reminders

Please remember that images “puzzle pieced” together to look like a single label, or images that will simply line up on the same side of a container must each be uploaded as separate files. For example, a brand label comprised of three different pieces should be uploaded and identified as three brand labels. Brand label mandatory information spread over two different front labels must also be uploaded and identified separately. Each file must contain one single image cropped of all white space and printer’s marks, and may be identified as "Brand/Front", "Back", "Strip", "Neck" or "Other". Also remember to disclose in the special wording section of the application if a single label is designed to look like multiple images but actually is not. This will prevent your application from being needlessly returned for correction.

TTB Expo: Come join us at the 2009 TTB Expo commencing June 24 -26, 2009, at the Northern Kentucky Convention Center in Covington, Kentucky. This year’s focus is on Compliance through Education. The three day event is a great opportunity to meet with TTB experts in tax and regulatory matters pertaining to alcohol, tobacco, and firearms. The new e-Gov Hall alone is a must-see, featuring the many advantages of TTB’s safe and fast internet-based systems.

Would you like to know what the COLAs Online buzz is all about? Then plan to attend the COLAs Online presentation at the Expo on Wednesday, June 24th at 1:30 pm. Learn how to register and begin electronically filing your applications for certificates of label approval. This session is designed for anyone not currently registered as a COLAs Online user. Attendees that currently use COLAs Online should visit the e-GOV Hall or the COLAs Online booth in the Exhibition Hall for technical assistance and answers to questions.

Additional information on the 2009 TTB Expo and how to register to attend is available at http://www.ttb.gov/expo/index.html. We look forward to seeing you there!