Alcohol Issues

Importing and Distributing Alcohol into the United States

TTB Product Labeling and Formulation Requirements

The Department of Treasury, Alcohol and Tobacco Tax and Trade Bureau, regulates the content and registration of wine, beer and liquor, as well as labels associated with such products. Prohibition may be over, but it is not dead in the U.S. Alcoholic products must comply with the Federal Alcohol Administration Act, the Alcoholic Beverage Labeling Act of 1988, the Internal Revenue Code, and many (many) State and Local Alcoholic Beverage Commissions throughout the U.S.

Importers of alcohol must hold federal and state permits (and sometimes local and city permits). Each state regulates the distribution of alcohol a little differently, and everyone takes their tax along the way.

Alcoholic beverage labels must include certain mandatory information and they must be approved before alcohol bearing the labels may be imported or distributed in the U.S. It is critical to ensure your product labels comply with U.S. requirements. Failing to do so will result in failing to obtain the required federal label approvals. Imported alcohol lacking label approvals will not be released by Customs to the importer or consignee.

In some cases, formulas for alcoholic beverages must be approved prior to even seeking a label approval. TTB may require the product to be tested before seeking the label approval. Each step takes time and money to accomplish.

TTB may require evidence of compliance with FDA or USDA requirements, depending upon the ingredients used to make the wine or statements made on the wine label (e.g. "organic" claims or the addition ingredients that are not Generally Recognized as Safe or "GRAS").

Certificates of origin and of process

Many alcoholic beverage imports must also be accompanied by a certificate of origin issued by a foreign government. Importers may need to comply with certification requirements under the Miscellaneous Trade and Technical Corrections Act of 2004 to ensure that the practices and procedures used to produce the imported alcohol constitute proper cellar treatment (wines).

FDAImports.com consultants and affiliated attorneys regularly assist domestic wine importers and foreign wine processors in complying with each step of the TTB, FDA, USDA, Customs and state requirements requirements.

Federal & State Permitting
Formulation Approvals & Pre-Import Letters
Label Design and Approval
Logistics, distribution, strategic planning
Import Inspections & Delays