While the Proposed Rule’s liberalization of Certificate of Label Approval (“COLA”) regulations reforms an overly burdensome regulatory system, the Labeling Rule fails to address two principal defects in the Bureau’s COLA scheme. First, at its core, the current COLA process is nothing more than the licensing of speech. As such, COLAs are unconstitutional prior restraints on liberties guaranteed to all Americans by the First Amendment. To ameliorate the unconstitutional impact of restraints on speech, the Rule should apply the process and post-publication enforcement of the proposed labeling requirements for COLAs related to personalized labels

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