June 26, 2019
Ms. Amy Greenberg
Director, Regulations and Rulings Division Alcohol and Tobacco Tax and Trade Bureau 1310 G Street NW
Washington, DC 20005
BY ELECTRONIC SUBMISSION
American Craft Spirits Association Comments on TTB Proposed Rulemaking 27 CFR Parts 4,5,7,14 and 19
Modernization of the Labeling and Advertising Regulations for Wine, Distilled Spirits and Malt Beverages
Docket No. TTB-2018-0007; Notice No. 176
Dear Ms. Greenberg,
The American Craft Spirits Association (ACSA) is pleased to submit the following comments and suggestions in response to the proposed rulemaking to 27 CFR Parts 4, 5, 7, 14, and 19 concerning the modernization of labeling and advertising requirements for wine, distilled spirits, and malt beverages.
ACSA, the national trade organization for craft spirits producers was formed to support the young and burgeoning small and independent distilling industry in the United States. Our most recent report, the Craft Spirits Data Project (2018), indicates over 1800 craft distilleries operating across all 50 states, with a total economic impact of $3.7 billion.
Members of ACSA are distilleries with a current DSP, annually removing from bond fewer than 750,001 proof gallons of product and having at least 75% equity or operational control. Members must also abide by the ACSA Code of Ethics to:
“Operate in an honest, transparent and non-deceptive fashion. We inform consumers truthfully and accurately about the sources and methods used to make our spirits through our labels, materials and communications. We expect fair dealing and respect amongst members. We obey all federal, state, and local laws.”
These comments reflect our position on the contemporary intersection of responsible public, policy and recognition of a modern and rapidly expanding marketplace, including the consumers demand for new and interesting products. Our goal is to provide meaningful and maximum transparency and accuracy in spirits labeling, advertising and marketing while also promoting a regulatory framework that allows for responsible innovation, creativity and growth in our industry.
ACSA is grateful for the opportunity to submit comments and to make recommendations on spirits labelling rules. Moreover, ACSA is thankful for TTB’s efforts to modernize and simplify the CFR. Given the evolving nature of the growing and innovative distilled spirits industry and the complexity of the CFR, ACSA formally requests that TTB consider a regular review of labeling (for example, every four years). By allowing the industry the opportunity to review and make suggestions to bring current 27 CFR Part 5, TTB will fulfill its public policy objectives, while allowing the industry to best serve consumers and remain competitive globally.
Chief Executive Officer
American Craft Sprits Association