Whoa, TTB cut way back on formulas

TTB put out Ruling 2016-3 at the end of September. It relates to spirits formula approvals, and is intended to cut some of the burdens for spirits companies and for TTB. It’s also sort of long. Word says it is 3,573 (carefully chosen) words. My mission is to break it down to 15% or less.

The gist is, TTB will help you avoid formula approval for many products in these big categories: vodka, rum, whisky, brandy. Some details, on each category, are below. If you want the whole story, you can go to the Ruling, and the elaborations at Industry Circular 2016-1 (for imports) and Guidance 2016-3. Rather than knocking out the formula approval requirements in the spirits regulations, TTB explains: “TTB will not accept for review new formulas submitted for products approved under this ruling. This ruling serves as the approval that is required by §§ 5.26, 5.27, and 19.348.”

http://www.bevlaw.com/bevlog/distilled-spirits/big-formula-changes-at-ttb

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