For several years, the Brewers Association (BA) has pushed for full funding for the primary federal regulatory agency responsible for the brewing industry—the Alcohol and Tobacco Tax and Trade Bureau (TTB). The BA has not been alone in this push. A broad industry coalition of beverage alcohol producers has long lobbied to provide more resources to the TTB, which is one of the most efficient government agencies in regard to funding relative to taxes collected.
TTB Funding Added
Advocacy efforts led to success when an additional $5 million was added to TTB’s FY 2016 appropriations to accelerate processing of formula and label applications. These funds were again approved for FY 2017, allowing them to hire 13 additional labeling and formulation specialists. Ten were working as of June 28.
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At the recent Wine, Beer & Spirits Law Conference in Portland, Ore., Anthony P. Gledhill, chief counsel at the TTB, described how these funds have improved function. Through August 2017, the TTB had received 156,809 COLA (certificate of label approval) applications, which represented a 5.7 percent increase compared to the same time period in 2016. Of these applications, 31,396 were for malt beverages, up 15.4 percent versus the same time period the previous year. The vast majority of those applications (97.5 percent) are now electronically submitted.
In mid-2016, label approval processing times were averaging 24 days for malt beverages. With additional resources and staffing, the goal for label approval turnaround was 10 days by the end of FY 2017. As of September 11, processing time had dropped to two days!
Similarly, the TTB has worked to reduce formula processing times. The BA played another role by petitioning the to increase the number of traditional ingredients that are allowable in beer without a formula approval. The TTB first loosened formula requirements in 2014.
A secondary ingredient exemption in response to a follow-up petition from the Brewers Association was approved in 2016.
As a result of these petitions and increased resources, the processing time for formulas had dropped to five days as of September 11.
Work remains on permit processing. Although the 53-day average processing time in August 2017 was a sharp improvement from the average processing time of 178 days in August 2016, the TTB recognizes the need for additional improvements. Many of these will come in the next version of Permits Online (PONL), expected in FY 2018.
These are exactly the types of improvements the Brewers Association cited in lobbying for full TTB funding. We will continue to work with our Congressional champions to ensure these improvements stay in place, and will continue to collaborate with the TTB on other ways to streamline the regulatory process for small and independent brewers.