TTB Proposes Modernization of Qualification Requirements for Brewer’s Notices

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The Tax and Trade Bureau recently published Notice No. 212, Modernization of Qualification Requirements for Brewer’s Notices, in the Federal Register and is now accepting comments on this proposed rulemaking.

With a goal of reducing burdens on industry members, the proposed amendments address the following issues:

  1. Eliminating the collection of certain information from Brewer’s Notices;
  2. Replacing required narrative descriptions of the premises with more specific information;
  3. Extending deadlines for reporting certain changes in the brewer’s business from 30 days to 60 days;
  4. Streamlining procedures for brewers using new trade names by allowing trade name use upon notification and not requiring TTB approval;
  5. Allowing the maintenance of required records at locations other than the brewery premises through a notification rather than an application for an alternate procedure;
  6. Clarifying which individuals are required to submit statements of financial interest in the business in connection with an application for a Brewer’s Notice;
  7. Reducing the frequency of physical inventories for certain brewers and providing additional flexibility in the timing of inventories;
  8. Streamlining procedures for discontinuing business as a brewer;
  9. Allowing entities operating multiple breweries to secure one bond covering all operations; and
  10. Eliminating the requirement that brewers notify TTB before voluntarily destroying taxpaid beer off brewery premises.

The Brewers Association plans to submit comments on the proposed rule and also encourages individual members to read the proposed rulemaking and to submit comments if desired. To access all documents and comments received related to this notice of proposed rulemaking, see Docket No. TTB­–2022–0006.

Comments are due by August 8, 2022, and can be electronically submitted using the Regulations.gov comment form for this notice. TTB can, and often does, extend comment period deadlines, although there is no guarantee that they will do so. Any member submitting comments is welcome to share those directly with the BA by emailing them to Pete Johnson, who also may be contacted with any questions.