What COLA Means in the Wine Industry

COLA in the wine business doesn't mean cost of living allowance, it means certificate of label approval. Over the weekend, we had a visitor to our winery who is a graduate student at Yale. During the course of our conversation, he mentioned that while he was in Indiana, we worked for the TTB. We are very familiar with the TTB because of our close encounters during our label approval process.
Before getting our label approval I was aware of all of the regulations that apply to a US label. Here is a table of the regulations according to the BATF, Wine Labels, Vintages and Wine Regions:

Category	%Grape Variety
Political Area i.e. State	If a state is on the label, then 75% of the grape variety must be grown in that state
AVA	If an American Viticultural area is on the label, then 85% of the variety must be from that AVA
Vineyard Designation	If a vineyard is on the label, then 95% of the grapes must come from the designated vineyard and the vineyard must also be in a designated AVA
Estate Bottled	If the label says estate bottled, then 100% of the grapes must come from vineyards owned or controlled by the winery (both must be in a designated AVA)
Grape Variety	If a grape variety is on the label, then 75% of the grapes must be of the stated variety
Vintage	If a vintage is on the label, then 95% of the grapes must come from the year stated
Produced/Made and bottled by	If the label includes produced/made and bottled by, then 75% of the grapes must be fermented, aged, and bottled at the indicated location
Cellared/vinted and bottled by	If the label includes cellared/vinted and bottled by, then it does not necessarily mean that the wine was fermented at the indicated location
Reserve	If the label includes the word reserve, that designation has no legal meaning in the U.S.

In addition to the above regulations, my husband and I ran into another rule that made our COLA take a little longer. When we were getting approvals for our white wines, there was no problem because all of our wines are 100% what they are on the label. However, when it came to making labels for our Cabernet sauvignon and Cabernet franc blend and our Cabernet sauvignon, Cabernet franc, and Barbera blend, the word "blend" threw a red flag. If a label contains the word "blend" then the percentage of the grapes that constitute the blend must be somewhere on the label. Winemakers can circumvent this regulation by calling their "blend" anything they want. Our friends at Paumanok call their blend Assemblage, which is very classy. Many wineries call their blend "Claret". Here is a recent wine that exemplifies that wording. It is from Linden Vineyards and their blend is called "Claret".

Jim Law chose to put the composition of his blend on the back label which tells you that the Claret is made of a blend of 50% Cabernet Sauvignon, 30% Merlot, 16% Cabernet Franc and 4% Petit Verdot. However, by calling his blend "Claret" he doesn't necessarily have to disclose what the percentages of red varieties goes into his "Claret".
In our case, we decided to drop "blend" from our label. It simplifies our label.
Eventually we were approved for the COLA for our red wines!