TTB Publishes Shutdown Plan: What It Means for the Beverage Industry

On October 1, 2025, the Alcohol and Tobacco Tax and Trade Bureau (TTB) released its updated shutdown plan in the event of a lapse in federal appropriations; here is a link – Treasury_TTB_Lapse_Plan.

The plan makes clear that almost all of TTB’s core business functions will halt if Congress fails to pass a budget. Out of 459 employees, 398 would be furloughed, with only 61 retained to handle limited “excepted” activities—mostly tied to tax collection and protecting government property.

What Continues

  • Processing of excise tax returns that include remittances
  • Minimal computer operations to prevent data loss
  • Protection of statute expiration, bankruptcy, liens, seizures
  • Protection of federal property and continuation of criminal enforcement

What Stops

  • Processing of permits, formula approvals, and Certificates of Label Approval (COLAs)
  • Laboratory services
  • Non-criminal investigations, audits, and most administrative functions
  • Drawback claims for non-beverage products

Operations in Puerto Rico will continue, since they are funded by a mandatory account, and enforcement of trade practice provisions under the FAA Act will remain active because of a separate three-year appropriation.

For industry members, the headline is stark: if the government shuts down, label approvals, permits, and formula reviews will grind to a halt. That means delays for anyone looking to bring new products to market or adjust existing approvals. The tax office will stay open, but innovation, compliance approvals, and customer service will not.

Here is the full plan for viewing:

Ashley Brandt

Hi there! I’m happy you’re here. My name is Ashley Brandt and I’m an attorney in Chicago representing clients in the Food and Beverage, Advertising, Media, and Real Estate industries. A while back I kept getting calls and questions from industry professionals and attorneys looking for advice and information on a fun and unique area of law that I’m lucky enough to practice in. These calls represented a serious lack of, and need for, some answers, news, and information on the legal aspects of marketing and media. I've got this deep seeded belief that information should be readily available and that the greatest benefit from the information age is open access to knowledge... so ... this blog seemed like the best way to accomplish that. I enjoy being an attorney and it’s given me some amazing opportunities, wonderful experiences, and an appreciation and love for this work. I live in Chicago and work at an exceptional law firm, Tucker Ellis LLP, with some truly brilliant people. Feel free to contact me at any time with any issues, comments, concerns… frankly, after reading this far, I hope you take the time to at least let me know what you think about the blog and how I can make it a better resource.

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