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: