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. Although the original comment period was set to close in March 2019, the TTB extended the comment period until the end of June 2019. 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.
 83 Fed. Reg. 60,562 (Nov. 26, 2018)
 84 Fed. Reg. 9,990 (Mar. 19, 2019).