rulemaking

TTB published a beast of a proposal, in late 2018, to radically transform the labeling and advertising rules for most alcohol beverages. On April 2, 2020, TTB published a substantially scaled back version of this proposal, as a final rule. The final rule makes quite a few important changes. The below list attempts to highlight some of the most important changes and observations to the TTB modernization of Parts 4, 5 and 7.

1. The new rules take effect on May 4, 2020.

2. TTB reviewed more than 1,100 comments from concerned parties.

3. The rule changes should not require any label changes and are intended to liberalize or explain.

4. TTB is dropping the proposal to define an “oak barrel” as a “cylindrical oak drum of approximately 50 gallons capacity.” Almost 700 comments opposed this change, and most of them suggested this would stifle innovation and unduly add costs.

5. Rather than require more elaborate statements of composition on distilled spirits specialty products, TTB may go back to considering something like FDA-style ingredient labeling someday in a separate rulemaking.

6. TTB is flexible about what spirits drinks should be recognized as cocktails.

7. TTB no...