So, what exactly does this shutdown mean for distillers,
brewers and vintners? Well, for
starters, there won’t be any label approvals, permit approvals or formula
approvals – so if you’ve got something new, maybe
you keep it in state.
Here’s
the TTB’s Shutdown plan, it includes a summary listing of exempt v.
non-exempt functions.
The activities most relevant to vintners, brewers and
distillers listed as exempt (i.e., TTB will be going forward with these
activities):
- Continuing the TTB computer operations to prevent the loss
of data in process (your previously subitted applications may be safe) - Protection of statute expiration, bankruptcy, liens and
seizure cases - Maintaining criminal law enforcement and undercover
operations - Processing of tax returns which include remittances
The activities that wineries, breweries and distilleries
will want to note are not-exempt and won’t be performed:
- Processing of permits, certificates of label approval, and
manufacturer of non-beverage products drawback claims - All non-criminal investigative activities, audit functions,
examination of returns, processing of tax returns that do not include
remittances - Laboratory services
- Most administrative functions not related to the safety of
life and protection of property
Notably, there’s also a tally of the employees left in limbo
by the shutdown. The tally states that only
35 out of 483 are likely to be kept working.
The TTB is not regularly updating its website for the time
being, so those looking for alcohol or alcohol law related info are going to
have to look elsewhere. We will keep you
posted on any updates.