As the alcohol beverage industry continues to grow and evolve, 2024 is shaping up to be a year of significant legal developments and trends. For wineries, breweries, distilleries, cideries, and meaderies, understanding the key legal changes and emerging issues is crucial to staying compliant and competitive. In this year-in-review post,…
Tag: TTB
TTB Broadens List of Beer Ingredients Exempt from Formula Approval Requirements through TTB Industry Circular 2024-2
The Alcohol and Tobacco Tax and Trade Bureau (“TTB”) released Industry Circular 2024-2 on December 5, 2024, which provides an expanded list of beer ingredients exempt from formula approval requirements. The new Circular added 24 additional ingredients that brewers can use in their beers without needing to obtain a formula…
TTB Reopens Notice and Comment Period for Standards of Fill for Wines and Spirits
TTB recently published a supplemental notice of proposed rulemaking (Notice No. 210A) in the Federal Register to reopen the comment period for standards of fill for wine and spirits. As many may remember, TTB published a notice of proposed rulemaking (Notice 210) in 2022 requesting comments about changing the standards…
TTB Suspends Multiple Permits for Consignment Sales
Last week, TTB reported that the agency suspended six (6) alcohol beverage permits between December 2018 and January 2019 for violations of consignment sale provisions of the Federal Alcohol Administration Act. Four wine wholesalers and two wineries faced a one-day stipulated permit suspension; a fifth wholesaler who was under investigation opted to…
Formula Wines: Enology & Regulatory Issues at 2019 Eastern Winery Expo
Join Denise Gardner of Denise Gardner Winemaking and me at the 2019 Eastern Winery Expo in Syracuse, New York March 19th through 21st for a discussion on formula wines and their enology and regulatory issues. A description of our event is provided below. Formula wines (those with non-wine flavorings like vanilla, chocolate or colors added) are taking…
TTB Revises Guidance Document on Personalized Labels
On September 5, 2017, TTB issued a new public guidance document, TTB G 2017-2, for personalized labels which the agency said supersedes its prior guidance TTB G 2011-05 but does not “completely change the underlying policy.” See TTB Public Guidance, TTB G 2017-2, Personalized Labels. Per TTB, the new guidance…
TTB Opens Comment Period for Three Proposed Wine Rules
On Wednesday, October 11, 2017, TTB announced that it would reopen comment period for three relevant proposed rules for the wine industry. The proposed rules were originally published in the Federal Register in 2016. The following rules have their comment periods reopened: Notice No. 160, Proposed Revisions to Wine Labeling and…
Cider Chat and Cider Law
I was recently interviewed in a podcast by Ria Windcaller of Cider Chat. We had a one-hour discussion on cider law, obtaining permits with TTB, labeling, advertising, social media, and various other topics that impact the cider community. It was a great experience, and the chat is available to listen…
Contemporary Wine Law Issues
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TTB Issues Temporary Rule Modifying Federal Regulations for Hard Cider
On January 23, 2017, the Alcohol and Tobacco Tax and Trade Bureau (TTB) issued a temporary rule (T.D. TTB–147) in the Federal Register that amends the federal regulations for hard cider. The temporary rule amends TTB regulations to implement changes made to the federal definition of “hard cider” in the Internal…
Submitting a Petition for a New Grape Variety to TTB
Last year, I represented a client before the Alcohol and Tobacco Tax and Trade Bureau (TTB) with respect to petitioning for the addition of a new grape variety for use as a variety on American wine labels. The grape variety, Loureiro, has been used on imported wines from Portugal and Spain….