Blog / May 18, 2026
22 of the Top 25 U.S. Wine COLA Filers Are Importers. 16 of Those File French Wine.
The conventional framing of TTB label compliance is that it’s a winery problem. The 2025 COLA data tells a different story.
We analyzed 104,018 wine and spirits COLAs approved by TTB in 2025 — the full public registry. The top 25 filers, by volume, accounted for 12% of all approvals. Of those 25:
- 22 are wine importers (TTB-registered with permit type “I”). Only one is a pure domestic winery.
- 16 list France as their top country of origin. Italy, New Zealand, and Mexico show up secondarily.
- The #1 filer alone — Wine Collective Direct LLC, a California-based wine importer — filed 1,036 COLAs in 2025, nearly four per business day, across 224 distinct brands (almost entirely from New Zealand).
Why this matters
First, it reframes who’s actually doing the most TTB compliance work. The industry talks about “small winery compliance burden” — and that’s real for the 8,800+ domestic producers in the long tail. But the volume happens at the importer level, where a single permit holder might manage hundreds of foreign labels a year.
Second, it shows where the compliance demand concentrates by origin. French wine alone drives the labeling workload for most of the top-25 filer set. If you’re building tools, training compliance staff, or just trying to understand where the friction is — the French import pipeline is where the data points.
There’s no real middle
8,945 unique permit holders filed COLAs in 2025. The top 100 of them account for 23.6% of all approvals. The other 8,845 each file fewer than 50 COLAs a year — most of them fewer than five.
You’re either a high-volume importer or a small producer in the long tail. The conventional “mid-sized winery” doesn’t really exist in COLA filing volume.
COLAClear pre-screens labels against the same regulatory framework TTB applies — for domestic wineries, craft distillers, breweries, and imported French wine alike. Free during public beta at colaclear.com.
Pre-check first. Submit once.
Related reading: 7 reasons TTB issues a “Needs Correction” notice covers the specific errors that drive rejections across this filer base. The two layers of label clearance explains where pre-screening fits in the COLA workflow.
Source: TTB Public COLA Registry, 2025 approvals (104,018 records). Permit-type classification per TTB Permits Online conventions.