Operating in the alcohol industry requires a federal permit from the Alcohol and Tobacco Tax and Trade Bureau (TTB) to manufacture, import, or distribute alcohol beverages and requires State and local licenses to distribute alcohol.  The permitting process, governed by 27 CFR Parts 19, 24, and 25, is intricate, requiring detailed applications and compliance with facility and operational standards. Our attorneys guide clients in selecting the appropriate permit type—such as a Distilled Spirits Plant (DSP), winery, or brewery permit—and prepare TTB Forms (e.g., Form 5100.31 for DSPs) to meet stringent requirements. We also guide our clients through the State and local alcohol licensing process.

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We provide comprehensive support for initial applications, renewals, amendments for facility expansions, or ownership changes, ensuring alignment with TTB’s enforcement priorities. Our expertise minimizes delays and reduces risks of permit denials or violations, enabling seamless business operations.

The alcohol industry is heavily regulated under the Federal Alcohol Administration Act (FAA Act) and TTB regulations, with requirements spanning production, labeling, advertising, and distribution. Our firm designs tailored compliance programs to address these obligations, including obtaining requisite formula approvals, Certificate of Label Approval (COLA) submissions approvals, and trade practice rules. We develop internal policies, train staff, and ensure accurate recordkeeping for production, inventory, and tax purposes. Our proactive approach identifies compliance gaps before TTB inspections, protecting your permit and reputation. As ongoing counsel, we review operational changes, such as new product launches or distribution agreements, to maintain compliance with federal and state laws.

TTB conducts regular inspections to verify compliance with production, recordkeeping, and tax requirements. Our team, leveraging insights from former investigators, conducts mock audits to prepare clients for scrutiny. We review production reports, inventory logs, and tax records to address vulnerabilities before inspections.

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If violations are cited, we craft corrective action plans, negotiate with TTB, and defend against permit revocation or penalties. From administrative hearings to federal court, we prioritize keeping your business operational with minimal disruption.

Introducing new alcohol beverages or modifying existing ones requires TTB approvals, such as formula submissions for distilled spirits or wine and Certificates of Label Approval (COLAs) under 27 CFR Part 4, 5, or 7. We assist clients in preparing submissions, analyzing formulations, and ensuring compliance with labeling and advertising standards, including health warnings and ingredient disclosures.

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Our services also cover navigating TTB’s sensory evaluation requirements and resolving classification disputes. By addressing regulatory hurdles early, we help manufacturers and importers bring products to market efficiently and compliantly.