- On Thursday, December 5, the Alcohol and Tobacco Tax and Trade Bureau (TTB) issued Industry Circular 2024-2, exempting 24 additional brewing ingredients from the agency’s formula submission and approval requirements. The Industry Circular responds to two petitions filed by the Brewers Association (BA) requesting further exemptions from formula requirements. The TTB has previously exempted over 50 brewing ingredients from formula requirements in response to earlier petitions by the BA.
- The Brewers Association continues to await possible new regulatory proposals on mandatory allergen, alcohol content, nutritional, and ingredient labeling. Earlier this year, the Brewers Association provided testimony and written submissions to the TTB explaining the needs of small and independent brewers. In particular, the Brewers Association has and will continue to advocate for standards that small businesses with limited resources can meet or, in the alternative, exemptions for small businesses and small batch products.
- The Brewers Association also keeps monitoring the status of TTB rulemaking to update its regulations governing industry trade practices, such as the tied-house and commercial bribery regulations. In extensive comments filed in 2023, the Brewers Association urged TTB to modernize its regulations to better address practices like category management, major venue sponsorships, crossover products, and new electronic commerce business models.
- The Brewers Association continues to work with the TTB in developing a revised form for brewery reporting and excise tax payment. The TTB recently expanded its pilot program for testing the form and instructions and expects to roll out the new form to the entire brewing industry in 2025. The Brewers Association believes the changes will simplify and streamline brewery paperwork and compliance.
- The Brewers Association continues to urge the TTB to act on a number of other sensible regulatory projects it has proposed to TTB. These include modernizing the regulations on advertising and labeling for non-alcoholic beer, updating the styles of beer (“malt beverages”) recognized by the TTB as sufficient to satisfy the TTB’s class/type labeling requirement, and streamlining and simplifying a number of regulations governing brewery operations.
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