FYI: TTB wants to ease distilled spirit permitting

The Alcohol and Tobacco Tax and Trade Bureau has been making an effort to streamline process and remove some of its red tape. Its latest move in modernization involves proposed changes to the regulations covering distilled spirit permits/registrations, including:

• Distilled spirits plants
• Alcohol fuel plants
• Users and dealers of specially denatured alcohol
• Tax-free alcohol users

They are also proposing to extend the period of time in which certain changes to your permit/registration need to be reported to TTB (from 30 to 60 days).

“The proposed changes are a result of an internal evaluation of our permit and registration application requirements,” the TTB notes. “The proposals also take into consideration relevant public comments submitted to the Treasury Department in response to its request for recommendations concerning regulations that can be eliminated, modified, or streamlined in order to reduce government burdens.”

Proposed amends for distilled spirits plants include:

• Eliminating various requirements to submit operational information. Specifically, TTB proposes eliminating eight (8) regulatory provisions requiring submission of information including, but not limited to, descriptions of production procedures and storage systems.
• Tailoring requirements to describe the DSP premises more narrowly to specifically correspond with statutory requirements, and consolidating requirements to provide descriptions of alternation operations with the general DSP premises description.
• Replacing requirements to submit narrative descriptions of DSP security with certifications that the applicant’s security measures will comply with enumerated regulatory requirements.
• Eliminating requirements to provide serial numbers of DSP equipment in the application, thereby allowing equipment to be reported in the aggregate where applicable and allowing a DSP application to be submitted prior to physical receipt of the equipment.

Other notable proposed amendments include:

• Extending deadlines for reporting certain changes in the business from 30 days to 60 days.
• Allowing regulated businesses to add or remove trade names by submitting a notification to TTB rather than applying for TTB approval.
• Allowing regulated businesses to maintain required records at a location other than the permitted premises without first obtaining TTB approval.

Take a look at the full Rule Proposal here if you dare. These changes should significantly reduce the time needed to complete an application for distilled spirits permits/registrations. If you have a comment to submit regarding this proposal, send ’em by February 1, 2022.