On October 19, 2018, the Alcohol Tax and Trade Bureau (TTB) published its Strategic Plan for Fiscal Years 2018–2022. TTB’s second strategic goal of the five-year plan is to “facilitate commerce through a modern labeling program focused on service and market compliance.” In line with this goal, TTB published “Modernization of the Labeling and Advertising Regulations for Wine, Distilled Spirits, and Malt Beverages” in the Federal Register on November 26, 2018. In 132 pages, this modernization proposes “to reorganize and recodify these regulations” to “reflect current TTB policy and modern industry practices.” TTB is seeking comment on the proposed modernization though March 26, 2019, and ADI believes that all interested parties — especially DSPs — should make a formal public comment to TTB about these changes. It is no exaggeration to say that our collective voice may help reshape the regulatory landscape of labeling distilled spirits for decades to come.

Before making any formal comment to TTB, ADI strongly encourages everyone to take the time to read TTB’s five-year plan and also the government’s recommendations for submitting effective comments:




The labeling and advertising modernization plan is very detailed, and there are several positive changes that could make the process of labeling much easier. Some of these include extension of age statements to all spirits classes minus neutral spirits (vodka), which will presumably make label applications for aged gin and some distilled specialty spirits easier. The plan also clarifies when and who may use “Distilled by” on their label.

There are also a few proposals that will be of interest to our community. TTB is proposing to define a barrel used for aging spirits as a “cylindrical oak drum of approximately 50 gallons capacity.’’ This new mandate should be a concern for both coopers and anyone maturing spirits in barrels smaller or larger than 50 gallons. In addition, TTB is proposing creation of new classes in the standards of identity, including “white whiskey,” although absent from these revisions are classifications for “American Single Malt Whiskey” or whiskeys finished in secondary oak casks.

TTB is asking for comment regarding the proposal’s impact on consumers and industry members, as well as if there are any other “significant changes” that should be made to the CFRs regarding distilled spirits. Formal comments must be made by March 26, 2019, and can be submitted online within Docket No. TTB–2018–0007 on Regulations.gov or by courier/mail that includes your name, mailing address and  reference to “Notice No. 176.” In addition, any comment from a company, guild or other entity should be submitted on letterhead. ADI believes that DSPs and all interested parties should take this opportunity to make their voices heard on this very important proposal.

To see the concerns that the distilling community is uncovering in this lengthy proposal, please follow the conversations at: http://adiforums.com/topic/10276-changes-to-cfr/