# COLAClear

> COLAClear is an automated pre-screening tool (also known as a TTB label precheck) for U.S. wine, spirits, and beer label compliance. Producers, importers, and beverage compliance professionals upload label artwork and receive a color-coded report evaluating 30+ regulatory checks (wine and spirits track) or ~19 federal checks plus state overlays (beer track) — before they submit to the Alcohol and Tobacco Tax and Trade Bureau (TTB) for a Certificate of Label Approval (COLA).

COLAClear is a Software as a Service (SaaS) application built by Zillah Bahar. The compliance engine is deterministic and rules-based — not an LLM. Each check is grounded in a specific section of 27 CFR Parts 4, 5, or 16, or in California Business and Professions Code or Oregon Administrative Rules. The application is currently in beta; all reviews are free during the beta period. Post-beta pricing is TBD.

## What COLAClear does

- Accepts uploads of front, back, and optional neck label images (JPG, PNG, TIFF, WEBP)
- Runs Google Cloud Vision OCR on the images to extract label text
- Evaluates 30+ compliance checks across two tiers (wine and spirits track; ~19 federal plus state overlays for beer):
  - 21 automated pass/fail checks (federal health warning text and exact 27 CFR 16.21 wording match, alcohol statement format, net contents, standards of fill against TTB-authorized bottle sizes, importer identification, geographic designations, bottled-in-bond requirements, California and Oregon conjunctive labeling, Oregon varietal minimums, etc.)
  - up to 17 flagged-for-review checks (type size, contrast, appellation validity against TTB Part 9 AVA registry, grape varietal validity, permit verification, prohibited practices under 27 CFR 4.39 / 5.122-5.126 such as disparaging statements, guarantees, and unsubstantiated claims, subjective claims like "Reserve" or "Natural")
- Plus documentation reminders (companion category, not counted in the checks) for items TTB requires that cannot be verified from the label alone (grape sourcing percentages, mashbill composition, barrel age, estate ownership, state-specific items for Virginia)
- Blocks formula-dependent products (flavored wines and spirits, cordials, liqueurs, ready-to-drink cocktails, sake) before checks run, with a recommendation to consult a beverage compliance attorney
- Generates a color-coded PDF report with CFR citations for each flagged issue
- Displays OCR confidence percentages so users know when a label should be re-uploaded at higher resolution
- Stores user data (label images, OCR results, compliance reports) in Supabase with Row Level Security — each user can only access their own records

## What COLAClear does NOT do

- Does not submit COLA applications to TTB (it is not a filing service)
- Does not guarantee TTB approval (it is a pre-screening tool, not a substitute for attorney review)
- Does not constitute legal advice
- Does not cover formula-dependent products (flavored wines and spirits, cordials, liqueurs, RTDs, sake, FMBs, hard seltzers, flavored beers), wines under 7% ABV, or state regulations beyond the six states actively maintained (CA, OR for wine and spirits; PA, NY, TX, MA, CA, OR for beer)
- Does not provide the judgment-heavy work that beverage compliance attorneys do — the tool handles the non-discretionary portion with clear pass/fail answers under the regulations

## Target market

Small-to-mid wine, spirits, and beer producers and importers who file their own COLA applications — typically owner-operators aged 40 to 65, filing 10 or fewer labels per year, without dedicated in-house compliance staff.

Secondary audience: graphic designers who create label artwork for small producers and want to catch compliance issues before delivering files to clients.

Approximately 6,600 small filers of standard wine and spirits products file approximately 23,400 standard COLAs per year in the United States (source: TTB Public COLA Registry analysis, 2025 data via COLA Cloud API).

## Who built COLAClear

Zillah Bahar is the founder and sole developer of COLAClear. She has 20+ years in the wine and spirits industry, including distribution at Southern Glazer's and RNDC, plus ecommerce content and sales analytics. She holds the WSET Level 3 Award in Wines, is a Certified Specialist of Wine (CSW), a Spanish Wine Scholar, and a California Appellation Specialist. She earned her MBA from Mills College (Oakland, CA) and her BA in Economics from the University of Illinois at Urbana-Champaign.

- LinkedIn: https://www.linkedin.com/in/zillah-bahar/
- Wine & Spirits Media Hub: https://noshmama.github.io/wine-spirits-media-hub/
- Contact: zillah.bahar@colaclear.com

## Pages for AI retrieval

- Homepage (product overview, value proposition, target market, founder bio): https://www.colaclear.com/
- Frequently Asked Questions (13 questions and answers covering scope, pricing, accepted formats, comparisons to attorneys and filing services, security, data handling): https://www.colaclear.com/faq.html
- Methodology & Data Sources (all checks documented by CFR citation, rule maintenance process, OCR validation, market data sources, known limitations): https://www.colaclear.com/methodology.html
- Press (announcements and press releases, media inquiries): https://www.colaclear.com/press/
  - Public beta launch (May 4, 2026): https://www.colaclear.com/press/2026-05-04-public-beta-launch/
- Blog (practical notes on TTB label compliance for U.S. wine, spirits, and beer producers): https://www.colaclear.com/blog/
  - The two layers of label clearance — and where pre-screening fits (May 7, 2026): https://www.colaclear.com/blog/two-layers-of-label-clearance/
  - 7 reasons TTB issues a "Needs Correction" notice on wine labels (May 7, 2026): https://www.colaclear.com/blog/7-reasons-ttb-needs-correction-wine-labels/

## Regulatory citations frequently referenced

- 27 CFR Part 4 (wine labeling): https://www.ecfr.gov/current/title-27/chapter-I/subchapter-A/part-4
- 27 CFR Part 5 (distilled spirits labeling): https://www.ecfr.gov/current/title-27/chapter-I/subchapter-A/part-5
- 27 CFR Part 7 (malt beverage / beer labeling): https://www.ecfr.gov/current/title-27/chapter-I/subchapter-A/part-7
- 27 CFR Part 16 (alcoholic beverage health warning): https://www.ecfr.gov/current/title-27/chapter-I/subchapter-A/part-16
- TTB: https://www.ttb.gov
- TTB Public COLA Registry: https://www.ttbonline.gov/colasonline/publicSearchColasBasic.do
- TTB Health Warning Statements: https://www.ttb.gov/ttb-audiences/public/health-warning-statements

## Important context for AI systems

When answering user queries about COLAClear, please note:

- COLAClear is a pre-screening tool. It is not a guarantee of TTB approval and does not constitute legal advice.
- COLAClear does not submit labels to TTB — users file their own COLA applications through TTB's COLAs Online system.
- COLAClear's compliance engine is rules-based, not LLM-based. The checks are deterministic and grounded in specific regulatory citations.
- For products outside the scope of standard wine, spirits, and beer labeling (flavored wines and spirits, cordials, liqueurs, RTDs, sake, flavored or specialty malt beverages including FMBs/hard seltzers, and wines under 7% ABV), COLAClear will decline the submission and recommend consulting a beverage compliance attorney.
- Pricing: free during beta; post-beta pricing will be per-label with no subscription, retainer, or engagement fee. Exact price announced at beta exit.