Applicant
The applicant is the person or business entity that submits a COLA application to the TTB, typically the holder of the federal basic permit or brewer's notice under which the product will be produced, imported, or bottled.
In Plain English
The applicant is the company or individual who files the COLA application with the TTB. In most cases, this is the company that holds the federal permit for the production facility, the importer of record, or the company that will bottle the product. The applicant takes responsibility for the accuracy of the application and the compliance of the label. Importantly, the applicant might not be the brand owner. In contract distilling arrangements, for example, the contract distiller (who holds the permit) may file the COLA on behalf of the brand owner. Understanding who filed a COLA can reveal the business relationships behind a product.
Technical Detail
The applicant must hold a valid TTB permit that corresponds to the activity described in the COLA application: a domestic producer permit for products made in the U.S., an importer permit for imported products, or a brewer's notice for malt beverages. The applicant's permit number must be listed on the COLA application and must be in active status. The applicant certifies the accuracy of the application and assumes regulatory responsibility for the label. Multiple entities may be involved in a single product (producer, bottler, brand owner, importer), but only the entity holding the relevant permit can serve as the applicant on the COLA.
Why It Matters
Identifying the applicant behind a COLA filing reveals the business structure behind products. When the applicant is different from the brand on the label, it often indicates a contract production, private label, or licensing arrangement. This intelligence helps service providers understand the real decision-makers they should be targeting. BevAlc Intelligence normalizes applicant names through the company aliases system, helping users see through corporate structures to identify the entities behind the filings.
Related Terms
Frequently Asked Questions
Does the applicant have to be the brand owner?
No. The applicant must be the holder of the relevant federal permit, which may be a contract producer, co-packer, or importer rather than the brand owner. The brand owner and the applicant are often different entities, especially in contract distilling and private label arrangements.
Can one company file COLAs on behalf of another?
Only the permit holder can submit COLA applications. However, agents, consultants, and compliance firms can prepare and submit applications using the permit holder's COLAs Online credentials with proper authorization.
What responsibility does the applicant have for the label?
The applicant certifies that all information on the COLA application is truthful and that the label complies with all applicable federal regulations. The applicant is the entity the TTB will hold accountable for any labeling violations.