Archives: December 2018

Government Shutdown Impacts Breweries

Planning to brew something that needs a formula approval or a COLA approval? Have a new facility in the works? If so, you might want to reconfigure your schedule because the government shutdown has caused the TTB to suspend many of its functions.  While you can still access certain functions on the TTB’s website, including Permits Online, Formulas Online, and COLAs Online, those applications will not be reviewed until after the government shutdown is over.  In addition, TTB personnel have been told not to report to work and, according to the website, are prohibited by federal law from volunteering their services during the shutdown.  This means that if you have a question or an issue with your application, nobody at TTB is available to assist you. Furthermore, TTB cannot update its website during the shutdown, so it is possible that some of the information will be outdated or otherwise inaccurate. We still recommend that you file the applications because there is no telling how long or short the shutdown will be.  Moreover, if others file and you do not, there could be a significant backlog once regular service is restored, which could further delay approval of your application. (more…)

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The TTB is Watching – Beverage Community Asked to Self-Report Violations

As the TTB enters a more user-friendly phase with its updated online registration portal, it is important to remember that it remains an enforcement arm of the federal government for the beverage alcohol community. In a somewhat ominous circular, the TTB requested that “each industry member review its promotional business practices to assure that such activities comply with the letter and spirit of the Federal trade practices laws and regulations.”  Not only did it ask for each community member to review its practices, the TTB also “encourage[d] each member of the regulated community to voluntarily disclose its own violations upon discovery.”  According to the circular, voluntary disclosure could lessen the actions, if any, taken by the TTB in response to those violations.  To assist with that compliance, the TTB circular provided a link to the Federal trade practice laws and regulations.  It should be noted that the TTB can seek to suspend or revoke basic permits or initiate criminal referrals.  (more…)

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