Contract Brewing & Alternating Proprietors: Who Gets the COLA?
For domestic brewers, a Certificate of Label Approval, commonly known as a COLA, authorizes the bottling of malt beverages, and when required, it must be obtained prior to bottling the malt beverage (including in cans and kegs). We’re often asked, “Who is responsible for obtaining the COLA in contract brewing and alternating proprietorship arrangements?” The quick answer is that the person who bottles the malt beverage is required to obtain the COLA.
Who is responsible for obtaining the COLA in a contract brewing arrangement?
Contract brewing is an arrangement in which one person pays a brewer to produce beer for them.
The contract brewer must qualify as a brewer and is responsible for:
- Obtaining a Brewer’s Notice
- Producing beer
- Keeping and maintaining brewing records
- Obtaining COLAs and formula approval (if required)
- Paying taxes upon removal from the brewery
Who is responsible for obtaining the COLA in an alternating proprietorship arrangement?
An alternating proprietorship is when two or more brewers take turns using the physical premises of a brewery.
Both the host brewer and the tenant brewer must qualify as a brewer and are both responsible for:
- Obtaining a Brewer’s Notice
- Producing beer
- Keeping and maintaining brewing records
- Obtaining COLAs and formula approval (if required)
- Paying appropriate taxes upon removal from the brewery
USDA: National Organic Standards Board Meeting
 TTB-regulated industries may find this notice of interest.
SOURCE: Federal Register / Vol. 87, No. 120 /Thursday, June 23, 2022
AGENCY: U.S. Department of Agriculture, Agricultural Marketing Service
ACTION: Notice of public meeting
SUMMARY: The Agricultural Marketing Service (AMS), U.S. Department of Agriculture (USDA), is announcing a meeting of the National Organic Standards Board (NOSB). The NOSB assists the USDA in the development of standards for substances to be used in organic production and advises the Secretary of Agriculture on any other aspects of the implementation of the Organic Foods Production Act (OFPA).
DATE: An in-person meeting will be held October 25–27, 2022, from 8:30 a.m. to approximately 5:00 p.m. Pacific Time (PT) each day and will include a virtual broadcast. The NOSB will hear oral public comments via webinars on Tuesday, October 18, 2022, and Thursday, October 20, 2022, from 12:00 p.m. to approximately 5:00 p.m. Eastern Time (ET). The deadline to submit written comments and/or sign up for oral comment is 11:59 p.m. ET, September 29, 2022.
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