Advocacy Submits Comments on TTB’s Proposed Rule for the Modernization of Permit Application Requirements for Wine Premises
On October 2, 2024, the U.S. Department of the Treasury’s Alcohol and Tobacco Tax and Trade Bureau (TTB) published a notice of proposed rulemaking (NPRM) on Modernization of Permit Application Requirements for Wine Premises. If adopted, the rule would enact “deregulatory amendments” to its regulations to modernize and streamline the application requirements for wine premises, as well as relax some reporting requirements associated with changes to the business of proprietors of wine premises. The proposed rule is part of a broader effort initiated by TTB in 2017 to evaluate the information the agency collects from applicants for permit registration applications with the purpose of identifying ways to streamline the application process, reducing the burden on the regulated industry, and ensuring that the process collects only information that is necessary to meet the agency’s statutory obligations.
The Office of Advocacy believes these goals are commendable and the proposed rule will reduce regulatory compliance costs for small entities in the wine industry. Advocacy also recommends that TTB consider adopting additional amendments that could further reduce these costs through this rulemaking.
After listening to small businesses in the wine industry, Advocacy’s comment letter recommended that TTB amend section 24.120 to allow wine premises up to 90 days instead of 60 days to notify TTB of any changes in the information included in an approved application to establish wine premises. Advocacy recognizes that the proposal to allow an extra 30 days to notify TTB of such changes is a welcome change that will greatly help small businesses comply with these notification requirements while also maintaining operations with minimal staff and resources. However, small businesses in the industry have informed Advocacy that extending the deadline up to 90 days for small entities would better ensure small businesses can weather difficult or unexpected operational changes while still ensuring TTB is notified within a reasonable time.
Advocacy also recommended TTB include in the final rule additional information and details on how the upcoming online interface, myTTB, and the proposed rule will work in tandem to ensure any changes small businesses make to their operations and practices to comply with the proposed rule will not need to be changed again when myTTB is launched.
For more information, please contact Assistant Chief Counsel Graham Owens at (202) 205-6701 or Graham.Owens@sba.gov.
Document
Comment Letter – Modernization of Permit Application for Wine Premises (PDF, 63.2 KB)