TTB proposes some welcome changes to Brewer’s Notices

The Alcohol and Tobacco Tax and Trade Bureau (TTB) continues its recent quest to trim some fat in its processes and reporting criteria. The latest TTB rulemaking proposal would streamline much of the qualification requirements for Brewer’s Notices as well as cut back on the requirements for reporting certain brewery businesses changes. Some of these are a real breath of fresh air.

In terms of the potential changes to the range of information that brewers must submit with Brewer’s Notices, the proposed amendments include:

• Removing requirements that brewers intending to sell and serve beer on brewery premises designate and maintain a separate “tavern” area within the brewery for such activities, and including instead general provisions to account for beer sold and served to customers anywhere on brewery premises.
• Tailoring requirements to describe the brewery premises more narrowly.

TTB also is proposing these regulatory amendments that will ease up on some of the previous reporting protocols without creating any new obligations. Our favorites in bold:

• Extending deadlines for reporting certain changes to the brewer’s business from 30 days to 60 days.
• Allowing brewers to use new trade names by notifying TTB in lieu of amending their Brewer’s Notice.
• Allowing brewers to maintain required records at a location other than the permitted premises without first obtaining TTB approval.
• Reducing the frequency of physical inventories in certain circumstances and allowing greater flexibility in the timing of physical inventories within the inventory period.
• Allowing entities operating multiple breweries to secure one bond covering all brewery operations rather than separate bonds for each brewery.
• Eliminating the twelve day waiting period prior to destroying taxpaid beer off brewery premises.

So: Less work for everyone! Potentially, at least. Comment period is now open until Aug. 8. Submit your own comment here if you wish. The nerds out there can read much more about all of this from the docket itself.