Make Sure Your Labels Follow These New Guidelines From the TTB for “Serving Facts” Statements
In 2007, the TTB issued Notice No. 73, a proposed rule entitled “Labeling and...
Category: Circulars
TTB Circular 2013-1 applies winery, distilled spirit, and malt beverage advertising rules to every form of social media
The U.S. Tax and Trade Bureau released TTB Circular 2013-1, on May 13, 2013. ...
TTB Issues Guidance on Filling-out the Brewer’s Report of Operations – TTB 5130.9 and TTB F 5130.26
Ever take a look at BROP and scratch your head? Well, your life just...
TTB Guidelines for Promotional Programs with Retailers
Marketing is an inevitability, even for those of you who produce small batches that...
Access To The Premises Is a Vital Part of An Alternating Proprietorship Agreement
It’s an alt-prop Tuesday here at Libation. Today we’re taking a look at the...
TTB Issues a Not-So-Subtle Reminder on Tie-in Sales
Much like the tax code, almost as instantaneously as the government codifies an alcohol regulation, people start to look for ways around those regs. And when you offer examples of your rules in practice, every so often you’re going to have to update the circulars to keep up with changing industry practices. That’s what just happened with TTB Circular 2012-2. An update to 2003-3, it looks like a few reminders and some new information seemed necessary to ensure both the letter and spirit of the law were being enforced.
The circular offers some interesting examples, as did 2003-3. Restated from the previous circular, an important point concerns certain holiday mixes or brews that will be of interest to anyone offering holiday or seasonal products. Offering them to retailers, tied to your regular product is expressly in violation of the definition for “tie-ins” under 27 CFR § 6.72:
A retailer must purchase a certain amount of regular distilled spirits, whether bottled or cased, in order to be allowed to purchase distilled spirits in a special holiday container or packaging.
