Malkin Law’s contribution to the latest edition of Craft Spirits Magazine: “Ensuring Compliance With Third Parties” Some legal dos and don’ts when using third parties to promote your alcohol beverage brand. —

See below from ASCSA, just remember to follow FDA rules and regs: American Craft Spirits Association GUIDANCE FOR DSP PRODUCTION OF HAND SANITIZER AND SANITARY SPRAY Craft distilleries around the country are stepping in to help alleviate our national shortage of sanitizing solutions. Two products in particular are in high demand: 60% ABV hand sanitizer and 70% ABV sanitary spray for surface disinfection. ACSA is working closely with TTB and FDA to ensure DSPs have the appropriate regulatory guidance and other information needed to ensure proper production and distribution guidelines are followed, as well as standards for safety and efficacy. TTB Just released from TTB, March 18, 2020 at 6:00p.m. This special edition contains guidance for DSPs and Industrial Alcohol User permittees on producing ethanol-based hand sanitizers. Due to the Coronavirus 2019 (COVID-19) pandemic, the Acting Administrator of the Alcohol and Tobacco Tax and Trade Bureau (TTB) has found that it is necessary or desirable to waive provisions of internal revenue law with regard to distilled spirits, and therefore is providing certain exemptions and authorizations to distilled spirits permittees who wish to produce ethanol-based hand sanitizers to address the demand for such products during this emergency. Any existing DSP therefore can immediately commence production of hand sanitizer or distilled spirits (ethanol) for use in hand sanitizer, as described below, without having to obtain authorization first. These measures are generally authorized under authorities that apply in disaster situations, and as a result, are initially approved through June 30, 2020, with the…

The Craft Beverage Modernization and Tax Reform Act (CBMTRA) has no doubt benefited those in the alcohol beverage industry. The tax relief under the CBMTRA is set to expire at the 2019. Industry members, including the American Craft Sprits Association (ACSA), are working hard to extend the tax benefits under the CBMTRA indefinitely. If you want to learn about the following: Outlook of the current status of tax legislation and extension efforts; Possible impact to your clients on December 31, 2019; If and how other issues, like the impeachment proceedings, could impact the Congressional agenda. Then please join ACSA’s public policy counsel, James Hyland of the Pennsylvania Avenue Group, on October 16th at 3pm EST for a¬†complimentary webinar.

Posted in ACSA, alcohol beverage law, Craft Spirits, Distribution, TTB | Tagged ACSA, CMBA, Taxes | Comments Off