Bevlog & Articles

The Craft Beverage Modernization Act (CBMA) allows substantially reduced tax rates or credits for both foreign and United States alcohol producers. Some of this was temporary and cumbersome during the past few years, but now that these tax changes appear to be long term, TTB has developed an online system to administer the tax cuts. Most foreign producers should register with TTB if their alcohol products will be imported into the US.

This tax savings opportunity is coming up very fast, and begins in 2023. TTB is allowing signups beginning in late 2022. In the past, TTB had a much different system to handle the rules around this tax reduction.

The excise tax savings can amount to hundreds of thousands of dollars per year per distillery. Upon a proper registration, the excise tax could drop from $13.50 per proof gallon to as low as $2.70. This is an 80% reduction and would take a typical bottle of vodka from $2.14 in federal excise tax to 43 cents. This seems well worth the extra time and expense, for all but the very smallest producers. The tax reductions apply to beer and wine also.

Effective January 1, 2023, foreign alcohol producers who wish to qualify for reduced rates or credits will need to register their plant using...

At the outset of the COVID-19 pandemic, many in the alcohol beverage industry recognized a significant problem facing our communities and pivoted their production to alcohol-based hand sanitizer. These products were donated to first responders and provided to the public-at-large to provide a resource that quickly became a scarce commodity in the fight against the spread of COVID-19. In response to this desire to help, the Food and Drug Administration (“FDA”) issued several temporary policies beginning in March 2020 to help regulate the production of alcohol-based hand sanitizer.

As mass-produced commercial hand sanitizer became more widely available, we believe a majority of alcohol beverage producers returned to doing what they do best, producing high-quality craft products. However, if there are any producers still manufacturing alcohol-based hand sanitizer, this post is for you.

In tomorrow’s (October 13, 2021) Federal Register, the FDA will announce the withdrawal of the temporary guidance related to alcohol-based hand sanitizer production. Essentially, FDA has determined that there is plenty of available hand-sanitizer in the market and thus no need for continued use of alcohol in hand sanitizer production.

If you are currently manufacturing alcohol-based hand sanitizer following the FDA’s temporary guidance, you must cease production by December 31, 2021. Similarly, distribution of these products under FDA’s temporary rules must end by March 31, 2022....