As you bring your brand to market, you’re going to hear a lot of three letter words. But don’t worry, there’s really only one you need to be worried about: the TTB!
What is the TTB and what does it do?
The TTB is the main regulator for alcohol beverages in the United States of America. It stands for the Alcohol and Tobacco Tax and Trade Bureau. These are the friendly folks who help you get those pesky COLAs. (For some background on COLAs, see our other article here).
The TTB is a part of a big agency in DC called the Department of the Treasury. In old movies you may have heard of something called the ATF – the Bureau of Alcohol, Tobacco and Firearms – pretty much all the intense stuff.
Back in the 9/11 days, the government reorganized something called the Homeland Security Act and put in place the TTB. That’s really all you need to know about the TTB’s history unless you want to delve into the stacks and learn about Prohibition and all the changes it caused.
Why do we need the TTB?
The main function of the TTB is to make sure alcohol laws are fairly administered, and to collect taxes. The main tax that the federal government assesses is called an excise tax, and it’s paid by the permit holder (the importer or the distilled spirits plant, winery or brewery), when the goods are removed from bond. If you’re working with Helmsman, you pay this, if you’re working with a traditional importer, they’ll pay this.
It also helps make sure two things happen
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What you bring to market is safe for human consumption (the formula process); and
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What you put on the label is true (the COLA process)
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What are Basic TTB Permits?
Basic permits are the permits that allow you to produce, ship or import alcohol. They are the ones ultimately responsible for making sure Uncle Sam gets what he needs. They’re split up into importer, wholesaler and plant permits.
Working with Helmsman on an imported product, you rent our infrastructure, in essence. Basically it means that all the things the federal government needs you don’t have to worry about, because we worry about it for you. If you’re working with a plant license, you rent their basic permit infrastructure and you’ll need all the registrations in each state to be able to ship across state boundaries.
Formulas Required by the TTB
Formulas are required for every product shipped in the U.S., just some are pre-approved. Basically, this means you need to show your work to the TTB by providing a list of everything which goes into your product. The ingredients are checked against a list the FDA maintains called the Generally Recognized as Safe (GRAS) list. Helmsman can help make sure your formula is done correctly the first time!
What are COLAs for the TTB?
COLAs, or certificates of label approvals, are checked by specialists against a list of requirements to make sure there is no misleading advertising. Again, Helmsman helps our clients make sure this is done correctly, avoiding unnecessary delays!
