September 17, 2018
Trade and Commercial Regulations Branch
Regulations and Rulings
Office of Trade
U.S. Customs and Border Protection,
90 K Street NE, 10th Floor,
Washington, DC 20229-1177
I am writing on behalf of the American Craft Spirits Association, the only national trade group representing the small craft producer. ACSA represents the interests of over 1,800 craft distillers located across the U.S.
Our industry is relatively new. Most of our members have started their businesses in the last decade. Craft distillers believe we are bringing back a great American tradition that dates to our founding fathers.
As our growing industry understands it, the excise tax drawback has been a critical tool to facilitate growth of American exports and has functioned as intended when it was first created two centuries ago and further implemented with Trade Facilitation and Trade Enforcement Act of 2015 (TFTEA). Drawback is one of the few WTO-sanctioned export incentives that helps offset the risk when seeking to develop foreign markets.
As noted in other comments, beverage alcohol is highly regulated and is often subjected to numerous tariff and non-tariff barriers in markets around the world. Further, many foreign competitors benefit from large subsidies and marketing support from their governments. As a result, we believe the drawback program may become more important to our relatively new industry over time and help level the playing field and promote the continued growth of distilled spirits abroad.