Letter to TTB: Advocacy Comments on Modernization of Labeling and Advertising Regulations for Wine, Distilled Spirits, and Malt Beverages
On November 26, 2018, the Alcohol and Tobacco Tax and Trade Bureau (TTB) published a proposed rule titled Modernization of the Labeling and Advertising Regulations for Wine, Distilled Spirits, and Malt Beverages.[1] Although the original comment period was set to close in March 2019, the TTB extended the comment period until the end of June 2019.[2] This letter constitutes the Office of Advocacy’s (Advocacy) public comments on the proposed rule.
Advocacy is concerned that the agency’s certification that the rule will not have a significant economic impact on a substantial number of small entities lacks a factual basis. Advocacy suggests the agency revise the rule to reduce the impacts of the definition of “oak barrel” and to establish a new class and type for mead or publish a supplemental initial regulatory flexibility analysis (IFRA) to propose alternatives to the rule.
[1] 83 Fed. Reg. 60,562 (Nov. 26, 2018)
[2] 84 Fed. Reg. 9,990 (Mar. 19, 2019).