January 12, 2022
Dear Chairwoman DeLauro, Chairman Leahy, Ranking Member Granger, and Vice Chairman Shelby:
As Congress negotiates final fiscal year (FY) 2022 funding levels, we want to highlight the significant new duties that Congress imposed and the importance of appropriately funding the Alcohol and Tobacco Tax and Trade Bureau (TTB) at $149,330,000 to meet the needs expressed by the U.S. Department of Treasury in its June 2021 “Report to Congress on Administration of Craft Beverage Modernization Act Refund Claims for Imported Alcohol”* (“the Report”). The Report details plans for TTB to take over certain responsibilities from U.S. Customs and Border Patrol (CBP) related to imported beverage alcohol products by January 1, 2023. TTB will need to begin its preparations well in advance to perform these new responsibilities by the stated deadline. We also request the inclusion of additional bill language:
“Of that amount, $18,000,000 for investments in technology and human resources necessary to administer the Craft Beverage Modernization Act refund claims for imported alcohol.”
In the Report, the Department of Treasury notes, “Treasury currently estimates annual resource requirements of $12 million-$18 million and 35-45 [full-time employees] once fully implemented” to administer the import claims program that CBP currently manages. The Report, which was released following the President’s FY2022 Budget Request, notes the following resource needs:
To administer the CBMA import claims program, TTB plans to develop two separate modules in its planned online filing system, “MyTTB.”5 First, foreign producers seeking to assign CBMA tax benefits for their products will provide information directly to TTB through an online registration module.6 Second, an import claims module will allow importers to submit refund claims to TTB for CBMA tax benefits. Together, these two modules will enable TTB to receive import claims electronically and validate claims automatically by reconciling claim data with data submitted to CBP at the time of importation, as well as against the required assignments provided by foreign producers in the foreign producer module. Electronic claim filings will also enable TTB to develop risk targeting tools to help it identify high-risk claims for audit and investigation. Treasury’s ability to fully implement this approach is contingent on receiving sufficient resources.
Read more here.